Federal Mobility Budget Becomes Mandatory in 2027: What Employers Need to Know
From 1 January 2027, the federal mobility budget (FMB) will become mandatory for many Belgian employers. While the principle is simple, the conditions and timing are not. This article summarises the key rules and what employers should prepare for.
Who is affected?
The obligation applies to employers who:
-
have an average workforce of 50 employees or more, and
-
offer company cars to employees.
For employers with 15–49 employees, the obligation starts on 1 January 2028.
Employers with fewer than 15 employees remain exempt.
Employees are not obliged to choose the mobility budget. Employers are obliged to offer it.
The 36-month rule still applies
The existing 36-month waiting period remains unchanged.
Only employers who have made one or more company cars available to one or more employees for a period of more than 36 months (continuous or not) fall within the scope of the obligation.
In addition, the employer must still have at least one company car in use at the moment the mobility budget is offered.
This means the 2027 obligation does not apply automatically to every large employer.
Employers may require pillar 1 for specific roles
Under the new framework, employers may require certain categories of employees to choose a solution within pillar 1 of the mobility budget.
This is allowed if the requirement is based on objective criteria, such as the nature of the function or operational mobility needs.
Typical examples include:
-
sales roles,
-
technical or field-based functions,
-
roles where a car is necessary to perform the job properly.
These rules must be clearly defined and documented in the mobility policy.
Transition can follow existing car contracts
Employers may postpone the effective transition to the federal mobility budget until the end of the employee’s:
-
lease contract,
-
rental agreement,
-
or other usage agreement for the company car.
This avoids early termination costs and fleet disruption.
How this rule applies to company cars owned by the employer remains unclear and is expected to be further clarified.
Final thoughts
From 2027 onwards, the federal mobility budget becomes a structural obligation for large employers in Belgium.
The priority is full legal compliance — correctly, consistently and defensibly implemented.
At the same time, employers should avoid adding administrative complexity to an already fragmented mobility landscape.
Done right, the federal mobility budget is not just a legal requirement.
It becomes a clear and positive narrative towards all company-car-eligible employees: transparent rules, fair budgets and real choice within a controlled framework.
The difference is execution.
Clear policies, strict enforcement and automation are what keep costs predictable, administration minimal and employee expectations aligned.