What are the penalties for contractors, subcontractors and employers that fail to comply with the registration obligation?
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Every contractor and subcontractor that infringes Article 24, Article 34, Article 35, Article 36 or Article 37, second, third and fourth paragraphs, of the Programme Act of 26 December 2022 and its implementing decrees, as well as every employer that infringes Article 37, first paragraph, of the Programme Act and its implementing decrees, is subject to a level 3 sanction. For offences committed from 1 February 2026, the criminal fine is €2,000 to €20,000, or the administrative fine is €1,000 to €10,000. The fine may be multiplied by the number of workers concerned. For offences committed before 1 February 2026, the criminal fine was €1,600 to €16,000, or the administrative fine was €800 to €8,000.
Every contractor and subcontractor that infringes Article 24, Article 34, Article 35, Article 36 or Article 37, second, third and fourth paragraphs, of the Programme Act of 26 December 2022 and its implementing decrees, as well as every employer that infringes Article 37, first paragraph, of the Programme Act and its implementing decrees, is subject to a level 3 sanction:
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A criminal fine of €2,000 to €20,000; or
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An administrative fine of €1,000 to €10,000.
These amounts apply to offences committed from 1 February 2026.
For offences committed before 1 February 2026, the criminal fine was €1,600 to €16,000, or the administrative fine was €800 to €8,000.
The possibility of multiplying the fine by the number of workers involved in the established infringement must also be taken into account.
Content derived from www.socialsecurity.be.
Source for the fine amounts: Belgian FPS Employment.
Amounts before and from 1 February 2026: Belgian FPS Employment.