A weekly briefing on European HR, labour law and compliance developments for SME HR teams across the EU, UK, Switzerland and the Nordics.
Top story: Belgium’s wage indexation cap hits payroll across sectors
Belgium’s Programme Act of 30 May 2026 introduced a temporary cap on automatic wage indexation that took effect on 1 June 2026, and payroll teams across the country are now working through its first full quarter of implementation. The cap applies to all employees in both the public and private sectors covered by Belgian social security, making it one of the broadest pay-related reforms in Europe this year.
The mechanism works as follows: employees with a gross monthly salary of EUR 4,000 or below continue to receive indexation under the normal rules. For employees earning above EUR 4,000, the first 2% of cumulative indexation is calculated only on the first EUR 4,000 of salary. Once the cumulative indexation exceeds 2%, the full salary is indexed again for the portion above that threshold. In practice, a 2% indexation round produces a maximum increase of EUR 80 for higher earners during the capped period. The cap applies in two phases: from 1 June 2026 and again, in principle, from 1 January 2028, when the EUR 4,000 threshold will itself be index-linked. The Act also introduces a new employer social security contribution designed to offset the lost tax and contribution revenue resulting from the restricted indexation.
The timing of the impact varies by sector, because Belgian wage indexation does not happen everywhere on the same date. Some employers felt the effect from June, while others will see it only at their next scheduled indexation moment. For part-time employees, the salary must be assessed proportionally. For employees paid on a daily or hourly basis, employers need to calculate a monthly reference salary to apply the cap correctly.
What to do: Belgian employers should confirm that their payroll provider or system correctly applies the EUR 4,000 threshold, including the proportional calculation for part-time and hourly workers. Review the new employer social security contribution to understand the cost offset. Communicate clearly to affected employees: the cap does not freeze pay, but it does slow indexation for higher earners in a way that Belgium’s workforce is not accustomed to.
Also developing
Germany: The Federal Ministry of Labour and Social Affairs is preparing a draft bill to reform the Working Time Act (Arbeitszeitgesetz), expected to be published in the coming weeks. The reform has two major elements. First, it will make electronic time recording a statutory requirement, with employers obliged to record the start, end and duration of daily working time on the day it is performed. Paper-based records digitised later will no longer be permitted. Transition periods are planned for SMEs, and businesses with fewer than 10 employees may be exempt from the electronic requirement. Second, the bill is expected to allow collective bargaining parties to agree on a weekly maximum working time of 48 hours rather than the current daily cap of eight hours (extendable to ten). This would permit days of up to 12 hours within the weekly envelope, offering significant flexibility for project peaks, cross-border teams and shift work. What to do: German employers should audit their current time recording arrangements now. If you rely on trust-based working time with no electronic record, start planning the move to an electronic system. Where a works council exists, early engagement is essential: the introduction of electronic time recording will trigger co-determination rights.
Netherlands: Enforcement of the DBA Act (Wet DBA) against bogus self-employment has intensified throughout 2026 following the Dutch Tax Authority’s full resumption of inspections on 1 January 2025. A “soft landing” period remains in place until 1 January 2027, meaning no default fines for unintentional errors, but punitive fines can be imposed immediately where intentional false self-employment or gross negligence is found. In a significant policy shift, Minister Aartsen announced in March 2026 that the cabinet is scrapping the clarification component of the VBAR bill, which was meant to replace the DBA Act, because it caused too much market uncertainty. The new government’s coalition agreement of January 2026 instead commits to a separate Self-Employment Act. What to do: Dutch employers engaging freelancers should not rely on the soft landing as a shield. Review all freelancer arrangements against the existing criteria for genuine self-employment. Assess whether each engagement looks more like an employment relationship in practice, particularly where work is performed on-site, under direction and with fixed hours.
Norway: The automotive industry became Norway’s tenth sector with a generally applicable minimum wage on 15 June 2026, covering repair, servicing, maintenance, painting, bodywork and warehouse operations. Rates range from NOK 208 per hour for unskilled workers aged 18 or over to NOK 237 per hour for skilled workers with at least one year of experience. Travel, board and lodging expenses do not count towards meeting minimum wage requirements and must be paid on top. What to do: Employers in Norway’s automotive sector, including those posting workers to Norway, should verify that pay rates meet the new minimums and that travel and accommodation allowances are paid separately.
Austria: Since 1 January 2026, collective bargaining agreements can be concluded for employee-like freelancers (freie Dienstnehmer), introducing potential minimum wages, overtime pay and holiday entitlements for this category for the first time. The change, often referred to as “lex Lieferando”, responds to criticism of companies shifting workers to freelancer-like contracts to avoid employment law obligations. Separately, partial retirement rules now allow working hours to be reduced by 25% to 75% with employer agreement, and employees on partial retirement may refuse overtime. What to do: Austrian employers using employee-like freelancers should monitor their sector’s collective bargaining negotiations closely. If a CBA is concluded that covers these workers, the employer will need to adjust pay, leave and overtime arrangements accordingly.
On the radar
UK Employment Rights Act reforms (previously covered): the trade union rights statement, workplace access and third-party harassment duty all land on 30 October 2026. Tribunal time limits double to six months on 1 October.
EU Platform Workers Directive (previously covered): member states must transpose by 2 December 2026. Only Italy has a draft legislative decree under parliamentary review. Spain opened a public consultation in late April.
Germany, Federal Labour Court: recent rulings from March and May 2026 tightened the rules on pre-formulated severance clauses (exemption-from-work clauses must show a “predominant, protectable interest”) and confirmed that employees may submit a draft of their own job reference, provided the final document stays truthful and clear.
Netherlands pay transparency consultation: the consultation on the gender pay gap reporting template runs until 11 September 2026.
Sources
- EY Belgium: Belgium caps wage indexation as of 1 June 2026
- DLA Piper: Belgium introduces major reforms to automatic wage indexation
- L&E Global: Belgium, the wage indexation cap on wages above EUR 4,000 per month
- Addleshaw Goddard: Germany’s working time reform, draft bill expected in June 2026
- DLA Piper: Germany prepares shift to weekly working time limits
- L&E Global: Netherlands, soft landing enforcement moratorium for bogus self-employment partially extended in 2026
- Smarter Search: the Dutch Wet DBA in 2026, enforcement and VBAR update
- Norwegian Labour Inspection Authority: minimum wage rates
- The Local Austria: new laws in Austria in September 2026
- Oppenhoff: focus on German employment law, first half of 2026
Europe HR Compliance Pulse Weekly is an informational summary of publicly reported legal and regulatory developments. It is not legal advice. Always confirm obligations for your specific situation and market with a qualified adviser.
