Why must you draw up a training plan?
Following the “Deal for Employment”, an individual right to training has been established. A full‑time employee is entitled to a training credit of no fewer than five training days per year as from 1 January 2024.
To reach the threshold of five training days per year, certain sectors operate with a phased growth trajectory. For more information, you may consult the Employment Agreement 2025‑2026 on Lex4You.
In order to monitor compliance with this individual right to training, employers are required to draw up a training plan.
What about the FLA?
The abolition of the FLA has no impact on your obligation, as an employer, to establish a training plan. The FLA was merely a tool for recording training activities and will be replaced by an Individual Learning Account in 2027.
For more information on the abolition of the FLA, please refer to our news item “Federal Learning Account officially abolished”.
Practically speaking, employees retain their right to training. You must therefore continue to offer training and, if you meet the applicable conditions, draw up a training plan.
Which employers must draw up a training plan?
A training plan is mandatory if you employ at least twenty workers.
To determine whether this threshold is reached, you must take into account the number of full‑time equivalents declared on the last day of a period of four consecutive quarters. This number is calculated at the level of the legal entity.
For the year 2026, the workers declared to the NSSO on the last day of the following quarters must be taken into account:
- 1 October 2024 to 31 December 2024
- 1 January 2025 to 31 March 2025
- 1 April 2025 to 30 June 2025
- 1 July 2025 to 30 September 2025
What is a training plan?
Each employer employing at least twenty workers must establish a training plan, either in paper or electronic form. This plan must be communicated annually to the workers or their representatives no later than 31 March. The plan may cover several years with the agreement of the workers or their representatives.
Concretely, the plan must at least include the formal and informal training you intend to offer your workers. You must also specify the target group(s) concerned. In addition, you must consider gender equality and pay particular attention to specific groups that face greater difficulties in accessing the labour market.
What is meant by formal training?
Formal training refers to courses and traineeships designed by trainers or speakers which:
- are organised largely by the trainer or training institution;
- take place in a location clearly distinct from the workplace;
- are addressed to a group of learners;
- are designed or managed by the employer or an external organisation.
What is meant by informal training?
Informal training does not meet the criteria applicable to formal training but is nevertheless directly related to the job. It must meet the following conditions:
- a high degree of self‑organisation by individual workers or a group of workers regarding the timing, location, and content of the training;
- the training content meets the individual needs of workers in the workplace and is directly linked to the work and the workplace (including participation in conferences or trade fairs).
Which specific target groups must be considered?
When preparing your training plan, you must pay particular attention to training for workers who may face greater difficulties accessing the labour market, such as:
- workers aged 50 or over;
- workers with a disability;
- workers of a nationality from outside the EU (including workers with at least one parent holding such nationality);
- workers for occupations in shortage (professions for which employers find few or no suitable candidates in the sector).
In addition to these at‑risk groups, you must also consider gender equality. Access to training may not depend on the worker’s gender.
What is the procedure for drawing up the training plan?
As an employer, you must respect the rules of social dialogue within your undertaking. The procedure varies depending on whether a works council or trade union delegation exists.
Where a works council or trade union delegation exists
You must submit the draft training plan to the works council or the trade union delegation. This communication must take place at least 15 days before the meeting organised to examine the draft. The works council or trade union delegation must issue an opinion no later than 15 March. The final content of the training plan must be determined by 31 March at the latest.
Where no works council or trade union delegation exists
You must submit the plan to all workers no later than 15 March. The final content of the training plan must be determined no later than 31 March.
Retention of the plan and transmission to the FPS Employment
You must transmit the plan to the FPS Employment, Labour and Social Dialogue within one month following its entry into force. This transmission is carried out electronically via: FPS Employment, Labour and Social Dialogue [BE]
In addition, you must retain the training plan within your company. Your workers and their representatives must have access to it upon simple request.
What about sectoral training plans?
The law provides that joint committees may establish, via a collective labour agreement made binding by Royal Decree, the minimum requirements a training plan must meet.
This collective labour agreement must be filed with the Registry of the Directorate‑General for Collective Labour Relations (FPS Employment, Labour and Social Dialogue) no later than 30 September of the year preceding the year in which the conditions for drafting the plan must be applied.
For more information, please consult the website of the FPS Employment: CLA Search | FPS Employment, Labour and Social Dialogue (belgium.be)
Example for Joint Committee 200
In Joint Committee 200, a training CLA 2024–2028 has been concluded and a model training plan has been developed.
What are the consequences if you do not draw up a training plan?
There is no specific statutory sanction for employers who fail to draw up a training plan.
However, you may incur a level‑1 sanction if you fail to comply with a sectoral CLA made mandatory. In such a case, you may be subject to an administrative fine ranging from EUR 100 to EUR 1,000.
If your workers must follow mandatory training to perform their function, you must allow them to do so. Failure to do so exposes you to a level‑3 sanction, which corresponds to either an administrative fine of EUR 1,000 to EUR 10,000 or a criminal fine of EUR 2,000 to EUR 20,000. This fine is multiplied by the number of workers concerned.
What does Securex do for you?
If you wish to learn more about the preparation of a training plan, contact your Securex Legal Advisor at myHR@securex.be or find an answer on our MySecurex portal. In the “MySupport” search tool, we have centralised the most frequently asked questions from our clients so that you can obtain assistance quickly, even outside office hours.
Your workers may also follow training courses provided by Securex: Training for employees and companies | Securex
For this purpose, contact us at academy@securex.be
