Important Updates
Important Updates
October 17, 2025 | United StatesUnited States: Second Court Challenge to New H-1B Restrictions and $100,000 Fee is Filed
October 17, 2025 | European UnionEuropean Union/Schengen Area: Internal Schengen Border Checks Situation
October 17, 2025 | NigeriaNigeria: New Mandatory Insurance for Foreign Employees
October 17, 2025 | NigeriaNigeria: New Online Temporary Work Permit Submission Process
October 17, 2025 | ThailandThailand: Mandatory Online Work Permit and Foreign Worker Registration System Forthcoming
October 17, 2025 | United StatesUnited States: Second Court Challenge to New H-1B Restrictions and $100,000 Fee is Filed
October 17, 2025 | European UnionEuropean Union/Schengen Area: Internal Schengen Border Checks Situation
October 17, 2025 | NigeriaNigeria: New Mandatory Insurance for Foreign Employees
October 17, 2025 | NigeriaNigeria: New Online Temporary Work Permit Submission Process
October 17, 2025 | ThailandThailand: Mandatory Online Work Permit and Foreign Worker Registration System Forthcoming
October 17, 2025 | United StatesUnited States: Second Court Challenge to New H-1B Restrictions and $100,000 Fee is Filed
Subscribe
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
    Navigating Immigration Under the Second Trump AdministrationTravel & Mobility Considerations: Situation in the Middle EastImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsVietnamese ImmigrationView 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

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

Navigating Belgium’s Enhanced Limosa Declaration: Simplifying Compliance for Posted Workers

July 15, 2024

Navigating Belgium’s Enhanced Limosa Declaration: Simplifying Compliance for Posted Workers

Countries / Territories

  • BelgiumBelgium
  • United KingdomUnited Kingdom
  • European UnionEuropean Union

Related contacts

Wim Cocquyt

Wim Cocquyt

Client Engagement Director Europe

Brussels (Benelux), Belgium

Email

[email protected]

T:+32 (0)2 250 4875

Harry Goldstraw - web porthole

Harry Goldstraw

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels (Benelux)
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Wim Cocquyt

Wim Cocquyt

Client Engagement Director Europe

Brussels (Benelux), Belgium

Email

[email protected]

T:+32 (0)2 250 4875

Harry Goldstraw - web porthole

Harry Goldstraw

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels (Benelux)
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Wim Cocquyt

Wim Cocquyt

Client Engagement Director Europe

Brussels (Benelux), Belgium

Email

[email protected]

T:+32 (0)2 250 4875

Harry Goldstraw - web porthole

Harry Goldstraw

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels (Benelux)
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Wim Cocquyt, Harry Goldstraw, Victoria Kate Barber, Flavia Noris

In April 2024, Belgium introduced a new functionality to the Posted Worker Notification (PWN), known as a Limosa declaration. It is now possible to add up to 20 places of employment in one Limosa declaration, where it was previously only possible to add five work locations. This reduces the administrative burden and costs for employers when sending employees temporarily to multiple worksites in Belgium.

Understanding the Limosa and the importance of compliance

The Limosa regulations require employers to declare any foreign workers who are temporarily posted to Belgium for work purposes. Compliance with the declaration ensures posted employees are treated equally to local Belgian employees regarding minimum wages, safety standards, working hours and conditions.

One of the main reasons this declaration is crucial is to prevent “social dumping” within the European Union. This occurs when employers attempt to bypass the labour standards (like minimum wages or workplace safety regulations) of the destination country by employing foreign workers under the lower standards of their home country.

Although introduced long before the EU Posted Worker Enforcement Directive 67/2014 came into effect (April 2007), the Limosa declaration is the tool through which Belgium has implemented the objectives of the directive, and it is currently considered one of the most advanced and straightforward instruments of PWN across Europe.

Compliance with Belgian law is important as there can be legal consequences for both the foreign home company that sends their employees to Belgium, as well as the host company in Belgium that receives the employees.

Penalties range from criminal fines of €4,800 to €48,000 EUR, administrative fines of €2,400 to €24,000 EUR per breach, and even imprisonment of the home company staff or agents, and self-employed posted workers, for up to three years for severe breaches. Penalties for not filing a PWN are determined on a case-by-case basis, at the discretion of the national labour authority.

Additionally, as the host company in Belgium is also liable if there are posted employees on their premises without a Limosa, there is an increased importance for the home company to ensure this is in order to avoid that workers are unable to enter work sites causing delays to the provision of the service.

There are also reputational risks associated with non-compliance. If a company has been audited, the Belgian authorities can inform the national press of any non-compliance of the company, putting the organisation’s name on the local or perhaps even global stage.

Exploring the new functionality

Although there are serious penalties for non-compliance, Belgium is often regarded as one of the most accommodating countries for posting workers. In addition to this new possibility to add up to 20 places of work in Belgium in one Limosa declaration, it is also possible to file a so-called simplified notification covering multiple trips across a longer period.

For example, if an employee is temporarily working in Belgium for one week every month of the year, and each month the worksite in Belgium changes, the home employer would only need to file one notification which would cover all trips for the employee at each different worksite in Belgium.

Country comparisons

In contrast to the Belgian Limosa declaration, many other countries operate under stricter interpretations of the posted worker rules from the EU. While these laws aim to protect domestic labour markets (of the destination countries), they can pose challenges for businesses operating across borders and require detailed policies and protocols to ensure compliance as the requirements vary between the different EU countries.

A direct comparison of the flexibility of the Limosa declaration can be made with France, where restrictions introduced in May 2024 mean an employer can only provide up to five worksites in a PWN, as the French authorities consider a PWN with more than five worksites not precise enough.

For business travellers travelling for a period of up to three weeks, there is no need to file a PWN in Belgium. However, in Poland, for example, this would be required for each business trip. Likewise, the amount of information and documents required when filing the PWN in Belgium is simpler for companies compared to countries such as Austria and Luxembourg with extensive information and documentation requirements.

In these aspects, the Limosa system in Belgium is quite straightforward compared to systems in most EU countries, which can prove advantageous for employers.

Looking ahead

The evolution of the Limosa declaration reflects that the EU is taking an active role in ensuring member states efficiently apply the rules and make the PWN process less burdensome for employers.

Changes in government portals for PWNs have been observed in many EU jurisdictions directly following recent infringement proceedings and an EU Commission report. With this increased attention, businesses must also embrace these changes effectively. As an employer it is important, now more than ever, to have strong but flexible policies in place to be able to adapt and remain compliant.

Due to the complexity of each European country implementing the PWN rules differently, there is a general interest, at both the EU and national levels, to simplify the process. Belgium is at the forefront by increasing the flexibility for employees to be posted to an increased number of worksites and to allow multiple trips under a single Limosa declaration.

This simplified process is also more cost-efficient for employers and reduces the administrative burden of sending employees to Belgium, which in turn can reduce non-compliance.

However, with this simpler process, businesses who send employees to Belgium must have robust systems and policies in place to ensure compliance as it also brings increased auditing and attention from the authorities to ensure full compliance.

Need to know more?

For further information on the varied requirements for PWNs or questions related to ensuring employees can work in Belgium or other EU countries, contact the Fragomen Consulting Europe team at [email protected].

This blog was published on 15 July 2024, and due to the circumstances, there are frequent changes. To keep up to date with all the latest updates on global immigration, please subscribe to our alerts and follow us on LinkedIn, X, Facebook and Instagram.

Countries / Territories

  • BelgiumBelgium
  • United KingdomUnited Kingdom
  • European UnionEuropean Union

Related contacts

Wim Cocquyt

Wim Cocquyt

Client Engagement Director Europe

Brussels (Benelux), Belgium

Email

[email protected]

T:+32 (0)2 250 4875

Harry Goldstraw - web porthole

Harry Goldstraw

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels (Benelux)
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Wim Cocquyt

Wim Cocquyt

Client Engagement Director Europe

Brussels (Benelux), Belgium

Email

[email protected]

T:+32 (0)2 250 4875

Harry Goldstraw - web porthole

Harry Goldstraw

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels (Benelux)
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Wim Cocquyt

Wim Cocquyt

Client Engagement Director Europe

Brussels (Benelux), Belgium

Email

[email protected]

T:+32 (0)2 250 4875

Harry Goldstraw - web porthole

Harry Goldstraw

Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels (Benelux)
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Video

Oman Introduces a Golden Visa Program | #MobilityMinute

Manager David Makau discusses Oman's recent introduction of a Golden Visa program.

Learn more

Media mentions

The Stage: Actors, Dancers and Writers Set to Escape Visa Ban

Partner Louise Haycock highlights the inclusion of performing arts occupations on the temporary shortage list and what it means for international talent in the sector.

Learn more

Media mentions

Arts Professional: Creative Sector Must ‘Come Together’ to Give Artists Easier Access to Visas

Partner Louise Haycock highlights opportunities for easier access to overseas talent for the UK creative sector while guiding businesses through evolving visa rules.

Learn more

Blog post

British Citizenship for Adopted and Surrogate Children: What Families Should Know

Associate Amelia Haynes and Paralegal Clare Macmillan Bell discuss the legal considerations surrounding British citizenship for children born through adoption or surrogacy.

Learn more

Media mentions

Financial Times: Boom Time for Immigration Lawyers as US and UK Tighten Restrictions

Partner Bo Cooper provides insight on how evolving US and UK immigration policies, including recent H-1B changes, are shaping corporate mobility and compliance strategies.

Learn more

Video

Atividades Técnicas sob Status de Visitante | #MobilityMinute

O Diretor Executivo da Fragomen Brasil, Diogo Kloper, destaca uma atualização importante na política migratória brasileira, que muda significativamente o que estrangeiros podem fazer no país sob o status de visitante.

Learn more

Media mentions

Global Mobility Lawyer: Founders Without Frontiers: Navigating Immigration Rules for Start-Ups

Partner Rajiv Naik provides insight on how immigration frameworks across the UK, Europe and EMEA are evolving to support start-ups and entrepreneurial talent.

Learn more

Media mentions

The New York Times: Visiting the European Union? Expect to Give Your Biometric Data.

Partner Jo Antoons discusses the rollout of the EU's new Entry/Exit System.

Learn more

Media mentions

The Times: Bye bye, Dubai: why families are heading for Abu Dhabi

Fragomen is featured in The Times as a key immigration adviser highlighting Abu Dhabi’s rising demand for golden visas, especially among UK nationals seeking long-term, self-sponsored residency.

Learn more

Video

Important Update for Brazil-Bound Visitors | #MobilityMinute

Brazil Managing Partner Diana Quintas highlights Brazil’s visitor visa rules and what travelers should know.

Learn more

Blog post

Changes to Skilled Worker Dependants: How UK Government’s July 2025 Rules Affect Tech Talent

Senior Manager Kinka Tonchev and Paralegal Emily Whalley discuss how upcoming UK visa changes will affect skilled worker dependants and reshape tech sector mobility.

Learn more

Fragomen news

Partner Marius Tollenaere Contributes to Third Edition of Einwanderungsrecht

Partner Marius Tollenaere provides key insights on labour migration, procedures and employer obligations in the latest edition of "Einwanderungsrecht".

Learn more

Video

Oman Introduces a Golden Visa Program | #MobilityMinute

Manager David Makau discusses Oman's recent introduction of a Golden Visa program.

Learn more

Media mentions

The Stage: Actors, Dancers and Writers Set to Escape Visa Ban

Partner Louise Haycock highlights the inclusion of performing arts occupations on the temporary shortage list and what it means for international talent in the sector.

Learn more

Media mentions

Arts Professional: Creative Sector Must ‘Come Together’ to Give Artists Easier Access to Visas

Partner Louise Haycock highlights opportunities for easier access to overseas talent for the UK creative sector while guiding businesses through evolving visa rules.

Learn more

Blog post

British Citizenship for Adopted and Surrogate Children: What Families Should Know

Associate Amelia Haynes and Paralegal Clare Macmillan Bell discuss the legal considerations surrounding British citizenship for children born through adoption or surrogacy.

Learn more

Media mentions

Financial Times: Boom Time for Immigration Lawyers as US and UK Tighten Restrictions

Partner Bo Cooper provides insight on how evolving US and UK immigration policies, including recent H-1B changes, are shaping corporate mobility and compliance strategies.

Learn more

Video

Atividades Técnicas sob Status de Visitante | #MobilityMinute

O Diretor Executivo da Fragomen Brasil, Diogo Kloper, destaca uma atualização importante na política migratória brasileira, que muda significativamente o que estrangeiros podem fazer no país sob o status de visitante.

Learn more

Media mentions

Global Mobility Lawyer: Founders Without Frontiers: Navigating Immigration Rules for Start-Ups

Partner Rajiv Naik provides insight on how immigration frameworks across the UK, Europe and EMEA are evolving to support start-ups and entrepreneurial talent.

Learn more

Media mentions

The New York Times: Visiting the European Union? Expect to Give Your Biometric Data.

Partner Jo Antoons discusses the rollout of the EU's new Entry/Exit System.

Learn more

Media mentions

The Times: Bye bye, Dubai: why families are heading for Abu Dhabi

Fragomen is featured in The Times as a key immigration adviser highlighting Abu Dhabi’s rising demand for golden visas, especially among UK nationals seeking long-term, self-sponsored residency.

Learn more

Video

Important Update for Brazil-Bound Visitors | #MobilityMinute

Brazil Managing Partner Diana Quintas highlights Brazil’s visitor visa rules and what travelers should know.

Learn more

Blog post

Changes to Skilled Worker Dependants: How UK Government’s July 2025 Rules Affect Tech Talent

Senior Manager Kinka Tonchev and Paralegal Emily Whalley discuss how upcoming UK visa changes will affect skilled worker dependants and reshape tech sector mobility.

Learn more

Fragomen news

Partner Marius Tollenaere Contributes to Third Edition of Einwanderungsrecht

Partner Marius Tollenaere provides key insights on labour migration, procedures and employer obligations in the latest edition of "Einwanderungsrecht".

Learn more

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
  • UK Regulatory Requirements

Our firm

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

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Have a question?

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

© 2025 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.