The mandatory training plan: what must you do as an employer?

The training plan obligation applies to employers with 20 or more employees. If your company has fewer employees, you are exempt from this formal obligation. The legal basis is the law of 3 October 2022 (the 2022 labour deal, or Arbeidsdeal, chapter 9), further elaborated in the royal decree of 14 July 2024.

If you are unsure about the headcount, your payroll agency (sociaal secretariaat) can confirm the exact number.

Important: companies below the threshold of 20 employees do not escape training obligations entirely. Your employees' individual training right — federally at least 1 training day per year per full-time employee for companies with 10 to 19 employees, unless the collective agreement of your joint committee (paritair comité) provides otherwise — continues to apply, even without a formal training plan.

The timing of the training plan falls in the first quarter of each year:

• By early March at the latest: you submit the draft training plan to the works council — or, in its absence, to the trade union delegation or directly to your employees.
• By 15 March at the latest: the works council or trade union delegation issues its advice.
• By 31 March at the latest: the final training plan is adopted and remains valid for at least 1 year.
• Within one month of entry into force: you file the plan with the FPS Employment, digitally via transfer.werk.belgie.be.

If you only start in March itself, there is little room to run the consultation carefully. Ideally, therefore, start preparing as early as January.

The royal decree of 14 July 2024 sets out the minimum content. Your training plan must:

• list both the formal and informal training you plan to provide for the coming year;
• explain how that training contributes to the training efforts of your sector;
• pay attention to shortage occupations (knelpuntberoepen) within your sector;
• take the gender dimension into account;
• give specific attention to at-risk groups: employees aged 50 and over, employees with a foreign background and employees with a disability.

Your joint committee may impose additional content requirements by collective agreement. So do check whether your sector sets extra conditions — your sector fund is the best place to ask.

Formal versus informal: what is the difference?

Formal training consists of organised courses or traineeships with a programme and an instructor, for example a safety course, a language course or software training with a recognised training provider. Informal training covers learning activities directly related to the job but organised less formally, such as coaching on the work floor or self-study. Both count and both belong in your plan.

The training plan is not a unilateral HR document: social consultation is a mandatory step in the procedure.

• Is there a works council? Then you submit the draft to it and await its advice, by 15 March at the latest.
• No works council, but a trade union delegation? Then the delegation takes over that role.
• Neither? Then you inform your employees directly.

The advice is not binding, but you must genuinely request it and respect the timing. Document the consultation carefully: the training plan is kept within the company, and employees and their representatives can access it on simple request.

At present, no sanctions are provided for employers who miss the deadline or fail to draw up a training plan. That may change, however. The plan is kept within the company; employees and their representatives can access it on simple request.

It therefore pays to make the plan a structural exercise that starts each January, rather than waiting for a sanction regime that does not yet exist.

A training plan written in March and then left in a drawer is a missed opportunity. Preferably start from your employees' individual training right: with 20 or more employees, full-time employees are federally entitled to at least 5 training days per year, although the collective agreement of your joint committee may deviate from this. If you fill in those days concretely per role or team, you will not have to improvise in December.

For most joint committees there is a wide range of recognised training on offer, often with a contribution from the sector fund. Browse the bookable training offer for your sector on the sector pages, for example for construction, electricians or white-collar employees — or start from the full overview per joint committee, where you can immediately see which training courses you can book for your sector.

And drawing up the plan itself does not have to be an Excel exercise: Smart Lions automatically calculates the individual training right per employee and produces a legally compliant training plan, with training courses, attendance and evaluations in the same tool — considerably faster and less error-prone than loose spreadsheets. What's more, you choose which courses from this academy you want and import them directly into that training plan, from which you then enrol employees — no retyping required.

With Smart Lions you draw up a legally compliant training plan and manage training, attendance, training rights and evaluations in one tool. You start for free, whatever your company size; more extensive plans from € 10 per month (excl. VAT). Via this link you can also test the full application free for 30 days.

Create your training plan

Sources: FPS Employment – Training plans · FPS Employment – Individual training right · Filing the training plan – transfer.werk.belgie.be