04 May 2015

You may have read it in the newspaper: there will be some changes in respect of the meal vouchers. As from 1 January 2016 the paper meal vouchers will disappear and the electronic lunch pass will become mandatory for all employees. Paper meal vouchers can still be granted until 30 September 2015. In addition, the maximum employer contribution per meal voucher will increase. Below we give you an overview of the changes.

Introduction of the electronic lunch pass

Since 2011 employers can choose to either distribute paper meal vouchers or to grant its electronic equivalent: the so-called lunch pass. This choice must be confirmed by a collective agreement on sectorial or company level. If there is no union present within the company, the choice must be confirmed in the individual employment contract.

The end of the paper era

The current choice between the paper and electronic meal vouchers slows down the intended simplification and even means an increase of the administrative burden. After a favourable evaluation of the electronic alternative, the lunch pass, the system of electronic meal vouchers will be standardised on request of the social parties. The paper meal voucher will, hence, disappear.

The paper meal voucher can still be granted for working days till 30 September 2015. The expiring date of the paper meal vouchers granted in 2015 is limited to 31 December 2015. This avoids the simultaneous use of paper and electronic meal vouchers after this date. From 1 January 2016, the electronic lunch pass will be the only legal tender.


The electronic lunch pass reduces the administrative burden in hands of the employers, employees and the merchants.

For the employee, the electronic system is easier and more user-friendly. There will be no more need to count and validate meal vouchers in the supermarket. The lunch pass is a simple electronic chip card which can be blocked by the user in the event of loss or theft. The “voucher” or the available amount will be recharged on a monthly basis onto the meal voucher account of the employee and will be valid for 12 months.

The employer places his orders and does no longer have to distribute or send the paper meal vouchers to his employees afterwards. The risk of loss or mistakes will thus be reduced.

In practice

The abolishment of the paper meal voucher is still some months away. However we already would like to give you an overview of some points of attention when implementing the system of electronic meal vouchers. It is important that all legal requirements are met, because meal vouchers that do not meet all the requirements are treated as ordinary wages, and will be taxed accordingly.


The electronic meal voucher must meet the same legal requirements as the paper version:

  • The granting of meal vouchers is confirmed in an agreement (collective or individual);
  • Only one meal voucher may be granted per working day;
  • The meal voucher is personal (in name of a specific employee);
  • The expiring date of the meal voucher must be mentioned an may not exceed a 12 month period;
  • The own contribution of the employee amounts to EUR 1,09 (minimum); the employers contribution is limited to EUR 5,91.

Some supplementary conditions:

  • The number of vouchers, the amount and the own contribution of the employee must be mentioned on the monthly pay slip;
  • In order to use the electronic lunch pass the employer must be able to verify the balance and validity of the vouchers;
  • A recognized distributor distributes the vouchers;
  • The use of the electronic lunch pass must be free-of-charge for the employee (an exception is possible in the event of loss or theft).

If you currently grant paper meal vouchers to your employees based on a collective agreement, no new collective agreement has to be drawn up. It is, however, necessary to amend the collective agreement to the new legislation in respect of electronic meal vouchers. This has to be done before 1 January 2016.

If you decide to grant meal vouchers as a new advantage for your employees, this can only be implemented by concluding a new collective agreement on company level.

If it would not be possible to make a collective agreement on company level, you can still arrange the attribution of meal vouchers via an individual written agreement. This can be done as an annex to the employee contract. Existing individual agreements must be amended to the new legislation and must contain the mandatory references.

The labour regulations must also be verified. For example, the consequences of loss or theft of the electronic lunch pass must be regulated if meal vouchers are granted by an individual agreement.

Furthermore, the ordering and distributing of electronic lunch passes must be organized timely.

Increase to EUR 8 per day

On 6 March 2015, the Council of Ministers approved the draft Royal Decree which increases the maximum value of the meal vouchers by EUR 1. The draft has now been send to the Council of State for comments.

When the final Royal Decree will be approved, the maximum employers contribution will increase from EUR 5,91 to EUR 6,91. The maximum value of a meal voucher will thus amount to EUR 8. This increase will be effective as from 1 January 2016.

One last note: the National Labour Council has, on its own initiative, published an advice for the future electronic distribution of eco-vouchers.


Should you have questions on this subject or require assistance, please do not hesitate to contact your usual BDO contact or our Competence Center Employment Tax and Legal Services.