As 2025 draws to a close, it is important to prepare for 2026. Below you will find a checklist of the main steps to take to ensure a smooth start to the new year.
1. CLA 90 bonus
Employers have the option of setting up a collective bonus scheme to reward the achievement of objectives while benefiting from a favourable tax regime.
In this context, if an employer wishes to grant a bonus based on objectives to be achieved during 2026, the scheme must be introduced by 30 April 2026 at the latest.
2. Other performance-related bonuses
If the employer has agreed to set targets triggering the payment of a bonus and fails to do so before the end of the reference period (e.g. 2025 in the case of an annual reference period), the employees concerned may attempt to obtain payment of their bonus in full (Brussels Court of Labour, 8 January 2019, RG 2017/AB/661).
3. Collective annual leave
Collective leave is determined within the framework of a collective agreement. If no specific rules are established by the joint committee before 31 December 2025, it is up to the works council to conclude such an agreement. In the absence of a works council, this power is exercised by the trade union delegation and, failing that, a direct agreement must be concluded between the employer and the employees concerned.
4. Replacement days for public holidays
When a public holiday occurs on a Sunday or a normal non-working day (e.g. a Saturday), it must be replaced by another day. These days are determined using the same procedure as that applicable to collective holidays. Replacement days must be posted on the premises before 15 December of the preceding year, i.e. 15 December 2025 for the year 2026.
5. Global prevention and annual action plan
Each year, based on the global prevention plan – which lists the results of the risk analysis and plans the actions to be taken – an annual action plan must be drawn up. This plan specifies the objectives of the prevention policy and must be submitted to the Committee for prevention and protection at work before 1 November. If there is no such committee, it must be sent to the trade union delegation, and if there is no delegation, directly to the employees concerned. Your prevention advisor can assist you with these procedures.
6. Conversion of eco vouchers into equivalent benefits
In joint committee 200, eco vouchers can be converted into equivalent benefits. This conversion requires a written agreement with the trade union delegation or, in its absence, prior notification of the employees. It must be carried out before 31 October of the year of allocation. Other specific rules may apply within other joint committees.
Together with Beci, we wish you a smooth end to 2025 and already a very happy 2026.
Vincent Marcelle, Lawyer-Partner Mosal
Léa Frisson, Lawyer Mosal
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