Mobility Budget in Belgium

While the introduction of a mandatory mobility budget remains subject to legislative delays, employers should be aware that several other important changes to the mobility budget regime are already scheduled to take effect as of 1 January 2026. In addition to these substantive amendments, the minimum and maximum amounts for the mobility budget will also be indexed. Below, we provide an overview of the current state of play regarding the mandatory mobility budget, as well as a summary of the confirmed changes and updated thresholds that employers will need to consider in the coming year.

As part of the federal coalition agreement for 2025-2029, the Belgian government has proposed a shift from a voluntary to a mandatory mobility budget system. Under the proposed reform, employers providing one or more company cars to employees for a period exceeding 36 months—whether consecutive or not—would be legally required to offer a mobility budget.

Initially, this new requirement was scheduled to enter into force on 1 January 2026. However, recent developments have delayed the legislative process. As a result, the original timeline of 1 January 2026 now appears unrealistic.

It is anticipated that, once adopted, the legislation will provide for a one-year transition period (starting from the date of entry into force) to allow employers sufficient time to comply with the new obligations.

Next to this, certain exemptions would be foreseen for companies facing financial difficulties and the debate is still ongoing regarding whether and when small and medium-sized enterprises should be required to offer a mobility budget.

Lastly, to prevent abuse and avoid creating unworkable obligations, employers would still be allowed to exclude certain categories of workers from the mobility budget offer based on objective, non-discriminatory criteria. Here, the nature of the employee’s function can be a decisive factor. For example, for a sales representative who is constantly on the road, it is questionable whether they could realistically do without a company car provided by the employer.

KPMG will continue to closely monitor further developments as the legislative process resumes in the coming weeks.

As it stands, several changes to the mobility budget are already set to take effect from 1 January 2026 under the current legislation and cannot be overlooked.

From 1 January 2026, only fully electric vehicles will qualify as environmentally friendly under the mobility budget. The current option to select a car with CO₂ emissions below a certain threshold (until 31 December 2025: max. 95g CO₂) will be abolished. The zero-emission requirement will apply to all company cars purchased or leased under Pillar 1 from this date onwards (i.e., where the order form is signed or the lease contract is concluded on or after 1 January 2026).

From 1 January 2026, only zero-emission motorized vehicles will be eligible under this pillar (electric mopeds, electric motorcycles, three wheelers…). The zero-emission rule will apply to all such vehicles purchased or leased from this date onwards by the employee.

From 1 January 2026, only zero-emission vehicles will be permitted for the allowed shared mobility solutions such as taxis and Ubers, vehicles used for carpooling and car sharing (for example Cambio). 

It is essential that employers update their policies and internal documentation accordingly and clearly communicate these changes to their employees. Furthermore, there are practical challenges for employers in verifying compliance when employees submit reimbursement requests for these expenses. For example, it may be difficult for an employer to retrospectively confirm whether a zero-emission taxi or shared vehicle was actually used.

Since 1 January 2022, the mobility budget allocated to an employee must be at least EUR 3,000 and may not exceed one fifth of the employee’s gross annual salary, with an absolute cap of EUR 16,000 per calendar year. These amounts are indexed annually. For 2026, the minimum mobility budget will be EUR 3,233, while the maximum will be EUR 17,244.

Employers must ensure compliance with these thresholds at the following times:

• When determining the mobility budget amount (i.e., when an employee starts with the mobility budget);
• Upon any job change or promotion;
• On 1 January of each year.

Employees currently capped at EUR 16,875 may be eligible for a higher mobility budget in 2026. Changes in salary may also impact the calculation of the 20% cap for the mobility budget.

KPMG can assist employers in navigating the evolving landscape of the Belgian mobility budget. Our team of experts can provide guidance on compliance requirements, help you update your internal policies, and ensure your organization is prepared for both the confirmed and anticipated changes. If you have any questions or need assistance, please contact your trusted KPMG advisor or reach out to us directly.