BELGIUM Law and Practice Contributed by: Chris Engels and Julie Devos, Claeys & Engels
• 2027: companies with more than 5,000 employees and turnover exceeding EUR1.5 billion; • 2028: companies with more than 3,000 employees and turnover exceeding EUR900 million; and • 2029: companies with more than 1,000 employees and turnover exceeding EUR450 million. In February 2025, the European Commission introduced the Omnibus Simplification Package, which includes the “Stop-the-Clock” Directive (Directive (EU) 2025/794). This directive post - pones the transposition deadline to 26 July 2027 and defers the initial application phase for the largest companies to 26 July 2028. The second part of the Omnibus Package pro - poses substantive amendments to the CSDDD to simplify obligations, particularly for small and medium-sized enterprises (SMEs), while main - taining the EU’s sustainability objectives. This second directive is expected to be adopted by the end of 2025, after which member states will need to transpose the revised provisions. It is now up to the Belgian legislator to develop a national legal framework based on the directive. No draft legislation is available yet, so how Bel - gium will concretely implement this mandatory due diligence regime 2.2.3 Modern Slavery Legislation Belgium has a comprehensive legal framework addressing modern slavery, including child labour, forced labour, and human trafficking. Penalties for non-compliance include criminal sanctions, civil liability, and financial fines, with companies increasingly held accountable for human rights risks in their global supply chains.
Recent EU developments – particularly the Cor - porate Sustainability Due Diligence Directive (CSDDD), which still needs to be transposed into Belgian law – are expected to further strength - en Belgium’s legal tools for combating modern slavery and enhancing corporate accountability. Child Labour Belgium has ratified key ILO conventions on child labour, including Minimum Age Conven - tion No 138 and Worst Forms of Child Labour Convention No 182. These conventions require national laws to set a minimum age for employ - ment that is not lower than the age for complet - ing compulsory schooling and, in any case, not less than 15 years. Belgium has had legislation on child labour since 1889, which has been amended over time. Under Belgian law, employment of children under 15 years is prohibited. For those aged 15-18, there are restrictions on the type of work, working hours, and conditions. Child labour is crimi - nalised under Article 134 of the Belgian Social Belgium adheres to the EU legal framework on forced labour, which prohibits compelling indi - viduals to work under threat, coercion, or decep - tion. Belgium also enforces the EU Conflict Miner - als Regulation, requiring companies importing tin, tantalum, tungsten, and gold from conflict- affected or high-risk areas to conduct due dili - gence to ensure their supply chains are free from human rights violations, including forced labour. On 19 November 2024, the EU Council adopted the Forced Labour Regulation (FLR), which pro - hibits forced labour products from being placed Criminal Code. Forced Labour
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