• Insights

Belgium: EU Intra-Company Transferee Permit Implementation Delayed

July 29, 2021

insight-news-default

Country / Territory

  • BelgiumBelgium

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

At a Glance

  • Belgium’s implementation of the EU Intra-Company Transferee (ICT) Permit, designed for intracompany transfers of managers, specialists and trainees from outside the European Union to Belgium for more than 90 days, has been delayed.
  • Brussels and Flanders have been accepting EU ICT Permit applications since October-November 2020, but corresponding EU ICT Permit cards are not being issued.
  • EU ICT Permit holders from other EU Member States can work at a Belgian group entity of their home employer for up to a maximum of 90 days in any 180-day period, provided the employer submitted a Posted Worker (Limosa) notification.
  • When implemented, EU ICT Permit card holders will also benefit from long term intra-EU mobility into Belgium under the advantageous terms of the EU ICT Permit Directive. 

The situation

The Belgian Council of Ministers approved legislation for EU Intra-Company Transferee (ICT) Permits to be issued in Belgium. However, since the backlogged Council of State must still render its advice on the final legislation, the publication and entry into force of EU ICT Permit has been postponed to the last quarter of 2021.

A closer look

As a reminder, the following will apply to an EU ICT Permit holder in Belgium when the Permit is implemented:

  • Eligibility for permit. The EU ICT Permit, which is a combined work and residence (single) permit, is available to managers and specialists with at least a higher education degree and trainees with a Master’s degree. Managers, specialists and trainees must have been working in the sending non-EU company for at least three months (in the Flanders and Walloon Regions) or six months (in the Brussels Region) to qualify for the EU ICT Permit, and should have their main residence outside the European Union when applying for the permit.
  • Salary requirements. Applicants should receive a salary similar to Belgian nationals in a comparable position. Regional governments have set specific thresholds that are presumed to meet this requirement, to streamline application processing.
  • Application process. The application process is similar to other single permit types. EU ICT Permit applications are submitted to the Regional Employment Authorities for final approval by the Federal Immigration office. Government processing times are expected to be the same as regular highly-skilled single permit applications, and cannot exceed 90 days (as compared to 120 days for regular single permits).
  • Family members work authorized. Dependents of both EU ICT Permit and Mobile ICT Permit holders can work in Belgium once they receive their dependent residence permits without a separate work permit. However, dependent family members do not qualify for an in-country change of residence status to an employee.

Impact

  • Permit applications. Brussels and Flanders have been accepting EU ICT Permit applications following partial implementation in 2020, but corresponding EU ICT Permit cards cannot yet be issued. Authorities have confirmed general Single Permit cards issued under this temporary arrangement can later be switched to an EU ICT Permit once these become available. In Wallonia, EU ICT Permit applications are not yet accepted.
  • Mobile EU ICT Permit applications to become available. When implemented, EU ICT Permit holders from another EU Member State seeking to work at a Belgian entity of their home employer for over 90 days will be able to apply for a Mobile ICT Permit with the Regional Employment Authorities. These individuals can, however, start working while their Mobile ICT Permit application is pending, provided the Posted Worker (Limosa) notification is submitted. Mobile ICT Permit applicants should receive a salary similar to Belgian nationals in a comparable position.
  • Notification required for short-term stay. EU ICT Permit holders from other EU Member States can work at a Belgian group entity of their home employer for up to a maximum of 90 days in any 180-day period, provided the employer submitted a Posted Worker (Limosa) notification.
  • Maximum stay: cooling-off period. After holding an EU ICT Permit for three years, permit holders must change to another Belgian permit type (e.g., Highly Skilled Permit), or must complete a cooling-off period and leave Belgium for at least three months before applying for another EU ICT Permit. Trainees can hold an EU ICT Permit for up to one year, but cannot extend this permit. The EU ICT Permit does not count toward permanent residency.
  • UK nationals. UK nationals not resident in Belgium before December 31, 2020 require work authorization. Eligible UK nationals will be able to apply for an EU ICT Permit once it is implemented in Belgium.

Background

  • EU ICT Permit background. The EU ICT Permit is suitable for intracompany transfers of managers, specialists and trainees from outside the European Union for more than 90 days, per the implementation of an EU Directive. The EU Directive aims to coordinate immigration rules for ICTs within the European Union and to allow intra-EU mobility rights. All other EU Member States have implemented the Permit (except Denmark and Ireland, which opted out of the Directive).
  • Benefits of Permit. Eligible EU ICT Permit holders can work in corporate group entities in other EU Member States following a streamlined notification or application process, offering the first truly intra-EU work authorization option. This significantly reduces the risk of noncompliance and the administrative burden for employers seeking to assign eligible staff to multiple EU locations.

Looking ahead

Fragomen will report when the EU ICT Permit is implemented in Belgium and the next steps for EU ICT Permit applicants in Brussels and Flanders, who may wish to exchange of their general Single Permit for an EU ICT Permit in order to benefit from intra-EU mobility rights.

Employers and interested applicants should consult their immigration professional for strategic mobility planning across the European Union.

This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].

Country / Territory

  • BelgiumBelgium

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Fragomen news

Fragomen Opens Denver Office, Strengthening Support for Colorado Employers

Fragomen opens a Denver office to expand immigration support for Colorado employers and growing businesses.

Learn more

Article

Foreign Birth Registration: Mistakes That Can Delay Irish Citizenship Applications

From documentation gaps and certification errors to missed deadlines, Senior Immigration Consultant Patricia Rezmives highlights 8 common FBR pitfalls and how applicants can avoid them.

Learn more

Blog post

Vous envisagez les États-Unis pour la rentrée prochaine ? C'est le moment de préparer votre visa E-2!

Entrepreneurs français : anticipez votre projet d’installation aux États-Unis avec un visa E-2. Découvrez les étapes clés pour préparer votre investissement, votre demande de visa et le déménagement familial avant la prochaine rentrée scolaire.

Learn more

Media mentions

Biometric Update: Fragomen-SICPA JV Adds IDEMIA Biometrics to Assemble End-to-End Identity Platform

Fragomen and SICPA expand their digital identity platform through a strategic collaboration with IDEMIA Public Security.

Learn more

Blog post

Document Legalization Is Becoming a Global Mobility Compliance Issue: Five Trends Employers Should Watch

In this blog, UAE Consular and Document Services Manager Minu Joseph examines five global legalization trends through a Middle East lens—and outlines how employers can prepare earlier to keep assignments on track.

Learn more

Blog post

Doing Business in Qatar: Growth and Workforce Mobility

In this blog, Corporate Services Manager Julia Ignatenko explores why businesses should coordinate company formation, regulatory compliance, leadership presence and workforce mobility from the outset.

Learn more

Awards

Fragomen Wins Immigration Provider of the Year: 2026 FEM APAC EMMAs

Fragomen won Immigration Provider of the Year at the 2026 FEM APAC EMMAs, and our Worldwide Immigration Trends Report 2026 received a Highly Commended recognition in the Thought Leadership category.

Learn more

Media mentions

Forbes: DHS Adds Immigration Rule Stopping H-1B Spouses From Working To Agenda

Partner Kevin Miner discusses DHS’ proposed rule to end employment authorization for certain H-4 spouses of H-1B professionals.

Learn more

Media mentions

Newsweek: Green Card Update: Major Change Announced for Sponsors

Counsel Brian Hunt discussed USCIS’ new ability to obtain credit information from green card sponsors and the potential implications for future regulatory actions.

Learn more

Awards

Partner Julie Lessard and Counsel Elsa Agostinho Recognized in the 2027 Edition of The Best Lawyers in Canada™

Partner Julie Lessard and Counsel Elsa Agostinho are recognized in the 2027 edition of The Best Lawyers in Canada™ for Immigration Law.

Learn more

Media mentions

Dubai Eye 103.8: Partner Ali Haider Joins The Agenda to Discuss Immigration Trends

Partner Ali Haider discusses immigration trends, visa appointments and the UAE’s continued efforts to attract global talent and investment.

Learn more

Blog post

Expanded Right-To-Work Scheme 2026: What UK Airlines and Aviation Contractors Need to Know

In their latest blog, Manager Adam Hickling and Immigration Consultant Daisy Dale examine the proposed changes, airline-specific risk scenarios and the practical steps organisations should consider before October.

Learn more

Fragomen news

Fragomen Opens Denver Office, Strengthening Support for Colorado Employers

Fragomen opens a Denver office to expand immigration support for Colorado employers and growing businesses.

Learn more

Article

Foreign Birth Registration: Mistakes That Can Delay Irish Citizenship Applications

From documentation gaps and certification errors to missed deadlines, Senior Immigration Consultant Patricia Rezmives highlights 8 common FBR pitfalls and how applicants can avoid them.

Learn more

Blog post

Vous envisagez les États-Unis pour la rentrée prochaine ? C'est le moment de préparer votre visa E-2!

Entrepreneurs français : anticipez votre projet d’installation aux États-Unis avec un visa E-2. Découvrez les étapes clés pour préparer votre investissement, votre demande de visa et le déménagement familial avant la prochaine rentrée scolaire.

Learn more

Media mentions

Biometric Update: Fragomen-SICPA JV Adds IDEMIA Biometrics to Assemble End-to-End Identity Platform

Fragomen and SICPA expand their digital identity platform through a strategic collaboration with IDEMIA Public Security.

Learn more

Blog post

Document Legalization Is Becoming a Global Mobility Compliance Issue: Five Trends Employers Should Watch

In this blog, UAE Consular and Document Services Manager Minu Joseph examines five global legalization trends through a Middle East lens—and outlines how employers can prepare earlier to keep assignments on track.

Learn more

Blog post

Doing Business in Qatar: Growth and Workforce Mobility

In this blog, Corporate Services Manager Julia Ignatenko explores why businesses should coordinate company formation, regulatory compliance, leadership presence and workforce mobility from the outset.

Learn more

Awards

Fragomen Wins Immigration Provider of the Year: 2026 FEM APAC EMMAs

Fragomen won Immigration Provider of the Year at the 2026 FEM APAC EMMAs, and our Worldwide Immigration Trends Report 2026 received a Highly Commended recognition in the Thought Leadership category.

Learn more

Media mentions

Forbes: DHS Adds Immigration Rule Stopping H-1B Spouses From Working To Agenda

Partner Kevin Miner discusses DHS’ proposed rule to end employment authorization for certain H-4 spouses of H-1B professionals.

Learn more

Media mentions

Newsweek: Green Card Update: Major Change Announced for Sponsors

Counsel Brian Hunt discussed USCIS’ new ability to obtain credit information from green card sponsors and the potential implications for future regulatory actions.

Learn more

Awards

Partner Julie Lessard and Counsel Elsa Agostinho Recognized in the 2027 Edition of The Best Lawyers in Canada™

Partner Julie Lessard and Counsel Elsa Agostinho are recognized in the 2027 edition of The Best Lawyers in Canada™ for Immigration Law.

Learn more

Media mentions

Dubai Eye 103.8: Partner Ali Haider Joins The Agenda to Discuss Immigration Trends

Partner Ali Haider discusses immigration trends, visa appointments and the UAE’s continued efforts to attract global talent and investment.

Learn more

Blog post

Expanded Right-To-Work Scheme 2026: What UK Airlines and Aviation Contractors Need to Know

In their latest blog, Manager Adam Hickling and Immigration Consultant Daisy Dale examine the proposed changes, airline-specific risk scenarios and the practical steps organisations should consider before October.

Learn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
September 4, 2026 | 🌐Fragomen Wins Immigration Provider of the Year: 2026 FEM APAC EMMAs
September 8, 2026 | United StatesFragomen Opens Denver Office, Strengthening Support for Colorado Employers
September 8, 2026 | 🌐Worldwide/Ukraine: Temporary Protection Status - Country-Specific Updates
September 4, 2026 | 🌐Biometric Update: Fragomen-SICPA JV Adds IDEMIA Biometrics to Assemble End-to-End Identity Platform
September 4, 2026 | DenmarkDenmark: New Immigration Pathway for Certified Employers Hiring Foreign Nationals from Select Countries
September 4, 2026 | 🌐Fragomen Wins Immigration Provider of the Year: 2026 FEM APAC EMMAs
September 8, 2026 | United StatesFragomen Opens Denver Office, Strengthening Support for Colorado Employers
September 8, 2026 | 🌐Worldwide/Ukraine: Temporary Protection Status - Country-Specific Updates
September 4, 2026 | 🌐Biometric Update: Fragomen-SICPA JV Adds IDEMIA Biometrics to Assemble End-to-End Identity Platform
September 4, 2026 | DenmarkDenmark: New Immigration Pathway for Certified Employers Hiring Foreign Nationals from Select Countries
September 4, 2026 | 🌐Fragomen Wins Immigration Provider of the Year: 2026 FEM APAC EMMAs
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.