Belgian public holidays 2025: deadline for communicating replacement days approaching

18 Nov 2024

In Belgium, public holidays that coincide with a Sunday or a day of usual inactivity in the company must be compensated with a day off on another day of normal activity. Determining these replacement days can be done at the level of the sector or, if no sectoral arrangement is in place, at the level of the company. Before 15 December of each year, the employer must inform the employees of the days off that compensate for public holidays that coincide with a Sunday or usual day of inactivity in the next calendar year.

2025 Public holidays 

These are the 10 Belgian public holidays in 2025:

New Year’s Day Wednesday 1 January 2025
Easter Monday Monday 21 April 2025
Labour Day Thursday 1 May 2025
Ascension Day Thursday 29 May 2025
Whit Monday Monday 9 June 2025
National holiday Monday 21 July 2025
Assumption Day Friday 15 August 2025
All Saints’ Day Saturday 1 November 2025
Armistice Day Tuesday 11 November 2025
Christmas Thursday 25 December 2025

General principles

According to Belgian law, if a public holiday falls on a Sunday or on a day of usual inactivity in the company (which in a lot of companies is Saturday), it must be compensated with a day off on another day of normal business activity. A day of usual inactivity refers to a day on which, according to the work regulations, no work is performed in the company. The replacement day will then be considered a public holiday for the employees involved.

How to determine replacement days?

The replacement of these public holidays can be organised at the level of the sector, via the adoption of a sector-specific collective bargaining agreement (CBA). If no sector-level CBA is in place, the day(s) off that compensate for the public holiday(s) that fall on a Sunday or on a day of usual inactivity in the company can be determined by the company’s works council. 

In the absence of a works council, the employer can come to an arrangement in this respect with the company’s union delegation or – in the absence of a union delegation – with the employees, collectively. 

If no decision is taken on one of these levels, arrangements can be made via individual agreement between the employer and the employee.

What if no replacement days are set at sector or company level?

If no replacement days are determined on the basis of the above principles, the public holiday that coincides with a Sunday or normal day of inactivity will be replaced with the company’s first day of business following the public holiday. For instance, if - in a company having Saturdays and Sundays as normal days of inactivity - a public holiday falls on one of those days, it will be replaced by the following Monday.

Information obligations by the employer

Before 15 December of each year, the employer must make available – at an easily accessible place on  the company’s premises – a dated and signed notice mentioning the following for the year to come:

  • the days off that have been set at the sector - or company level to compensate for the public holiday(s) that coincide with a Sunday or a normal day of inactivity in the company; and

  • the rules applicable regarding compensatory rest if the employees are asked to work on public holidays. 

In practice, the employer can send the employees a copy of this notice by email. 

The employer should also attach a copy of this notice to the company’s work regulations and send one to the social inspectorate services as well.

If you have any questions regarding the above, or are looking for more guidance in this respect, don’t hesitate to reach out; we’d love to hear from you.

Pascale Moreau

Lawyer - Partner, PwC Legal BV/SRL

+32 479 90 02 76

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