New cap on employer social security contributions for high earners

The Belgian Programme Act of 18 July 2025 provides for an exemption from employer contributions to the National Social Security Office (NSSO) on employee earnings above a certain salary threshold, scheduled to apply as from 1 July 2025. The expected threshold is EUR 85,000 per quarter for the remainder of 2025 and 2026 but this and further details are to be outlined in a royal decree.

The purpose of the measure is to enhance Belgium’s international competitiveness for highly paid knowledge jobs, curb the shift to other non-contributory forms of remuneration for employees, and limit the transition to self-employed status for highly paid employees.

Exemption from employer’s social security contributions

If the gross remuneration exceeds a certain threshold, the employer is exempt from employer social security contributions on the excess. The regulation applies to the private sector and to contractual employees in the public sector.

The exemption applies only to the basic employer contributions (approximately 25% for the private sector). Other employer contributions (totalling approximately 3%) remain payable on the entire salary, these include contributions to the Closure Fund for Enterprises, sectoral funds, the Occupational Accidents Fund, and the Asbestos Fund.

As such, the exemption does not apply to certain elements of remuneration, for example, supplementary pension premiums, company cars, mobility budgets, double holiday pay, severance payments, and profit-related bonuses.

In addition to the general exemption, the Programme Act also introduced several changes to certain specific employer social security exemptions and reductions (such as those for seafarers in the merchant navy and employees involved in scientific research, as well as the structural lump sum quarterly employer social security reduction  ) to avoid a double benefit.

Although the royal decree confirming full details of the exemption has not yet been published, the quarterly threshold is expected to be EUR 85,000. This is a high threshold and the exemption will benefit employers only in relation to relatively high earners.

If an employee has multiple jobs, the threshold will be apportioned between the jobs according to the ratio of the basic wage from the employment in the quarter to the employee’s total combined basic salary from all employments for that quarter.

In case of an incomplete quarter (e.g., when the employee does not work a full quarter or does not work full-time during a quarter), the threshold remains at EUR 85,000.

There will be no direct impact on statutory pension rights. As a reminder, if the total salary on an annual basis exceeds a certain threshold (EUR 80,485.32 for 2024), all contributions on salary above the threshold do not count towards the employee’s pension.

Example

Consider the example of a CEO with a basic annual salary of EUR 400,000 (EUR 100,000 per quarter). For the purpose of the example, other forms of salary such as company cars, supplementary pension premiums, or stock options are excluded, as are any specific exceptions from social security contributions. 

Based on an average employer’s aggregate social security contribution rate of 28% (in practice, this depends on the sector and the size of the company), the social security contributions payable for the employee under the old and new regulation are shown in the table below: 

By way of comparison, the contributions payable by a self-employed individual in 2025 with a quarterly professional income of EUR 100,000 would be substantially lower at EUR 19,983.12 (based on the quarterly maximum contribution cap of EUR 4,995.78, which excludes the administrative cost of the social funds).

Entry into force

The entry into force is scheduled for 1 July 2025. The royal decree is expected to set the quarterly threshold at EUR 85,000 per quarter for the remainder of 2025 and 2026 , and it is anticipated that this will be reduced to EUR 67,500 per quarter from 2027. These amounts will be indexed and need to be confirmed by royal decree.

Observations

In recent years, growing numbers of individuals in senior positions have opted for self-employed status. Whether the introduction of the new exemption from employer contributions on a proportion of the salary for high earners will limit this trend towards self-employment remains to be seen, as the threshold for the reduced employer contributions is still significantly higher than the threshold for capped social security contributions for self-employed individuals. It is also important to keep in mind the increased focus during NSSO inspections on identifying and addressing cases of sham self-employment.

Furthermore, this exemption could lead to a new reward dynamic for highly educated employees through the war for talent. The savings on the employer’s side could be used by employees as a bargaining tool to negotiate a new contract with a higher salary.

On a positive note, as some of Belgium’s nearest neighbours, such as the Netherlands, already have a cap on social security contributions, the introduction of the partial employer exemption in Belgium could increase Belgium’s competitiveness from an international perspective.