On 9 May 2025, the Flemish government approved the Flemish Minister for Work’s new concept note setting out a tightened and integrated labour migration policy based on 10 core principles. The proposed measures introduce stricter and more costly procedures for employers seeking to hire third-country nationals in Flanders. At the same time, the note promises significantly faster processing times for work permit applications, particularly for highly-qualified profiles.
1. Combatting fraud and abuse
The grounds for refusing or withdrawing a work permit will be tightened. Therefore, the following employers/employees may have their work permit applications refused:
- Employers who act as ‘gateways’ for non-EU workers;
- Employers who rely almost exclusively on non-European employees;
- Foreign employees who use forged or unlawfully acquired documents.
Employers who have committed unlawful acts will be excluded from the application procedure for a longer period of time, and this penalty will be extended to the company’s directors.
2. ‘Fast lane’ for highly-qualified professionals
The number of highly-qualified migrants in Flanders has dropped significantly in recent years. To attract more of such profiles, a ‘fast lane’ will be introduced for all highly-qualified applicants for a ‘single permit’ (‘gecombineerde vergunning’, i.e. a work permit and residence permit combined) with a maximum processing time of 15 days. This ‘fast lane’ has been in operation since 1 May 2025.
A disadvantage of this ‘fast lane’ is that the work permit part of the single permit for highly-qualified professionals will only be granted if the position to be filled corresponds to the level of higher education. An exception is made for nurses who take up another position in the healthcare sector while awaiting recognition of their foreign diploma. Highly-qualified professionals who wish to take up a lower-level position (e.g. mid-qualified positions) can therefore no longer obtain authorisation under the ‘highly-qualified’ category.
3. Stricter access for ‘bottleneck’ professions
The ‘Other’ category will be narrowed down to only medium-skilled bottleneck professions. This implies that it will no longer be possible to apply for single permits for low-skilled (bottleneck) professions. According to the concept note, this decision is explained by several key concerns: preventing domestic labour force displacement, protecting against social exploitation, and ensuring that available opportunities are prioritised for local jobseekers, particularly those who face barriers to entering the labour market. Seasonal work will remain an exception to this rule.
For the remaining ‘bottleneck’ professions falling under the ‘Other’ category, employers will still be required to conduct a labour market test, which includes publishing the vacancy on the VDAB website for at least 9 weeks. However, from now on employers will also be required to demonstrate that they have actively searched for suitable candidates in both the domestic and European labour markets, and that they are open to workplace-based learning opportunities. This must be supported through a comprehensive application file, documenting all recruitment efforts and clearly justifying why any candidates who applied, were deemed unsuitable, and why workplace-based training was not feasible. Simply publishing a vacancy on the VDAB website will no longer be sufficient to meet this requirement.
With the narrowing of the ‘Other’ category to only medium-skilled bottleneck professions, the salary thresholds for this category will be increased to align with the medium-skilled salary level.
In addition, the eligibility criteria for inclusion on the specific Migration list for ‘medium-skilled’ positions (which exempts listed professions from the labour market test) will be revised. Sectors are strongly encouraged to invest in workplace-based learning and training for niche professions with only a limited number of vacancies.
4. Shorter processing time for all applications
Not just applications for highly-qualified profiles (see point 2), but all single permit applications will be processed within a shorter time frame. By January 2026, the target for applications other than for highly-qualified profiles is an average of 30 days (with a maximum of 45 days during peak periods) for the work part of the single permit. A more efficient collaboration with the federal services is also under development to speed up residence permit processing at the national level and so reduce the entire processing time of the single permit even more.
5. Introduction of an application fee (retribution)
Starting from 1 January 2026, a EUR 200 fee (with a yearly indexation) will be charged per application (both the first-time and on renewal) that the employer will pay. This fee will come on top of the retribution that already has to be paid to the Federal Immigration Office for the residence part of the single permit (currently EUR 148 – also indexed every year). According to the concept note, this aligns with practices in other EU countries (like the Netherlands and Germany), and this fee would help to fund faster processing, better digital systems, and fraud control.
This retribution will also apply for a professional card (for self-employed contractors), but will not be charged for a work permit for a period of less than 90 days.
6. Streamlining diploma recognition
For regulated professions like nurses and care workers, a recognised diploma is required before they can start working. NARIC, the diploma recognition body, will simplify and speed up these procedures. New partnerships with foreign education institutions may lead to automatic or fast-tracked recognition of certain degrees.
7. Stricter supervision of religious workers
Foreign religious workers have historically benefitted from work permit exemptions. This is changing: applicants must now prove that there is a local shortage, and they may be screened by the Department of Internal Affairs. In the future, such applicants will also need to pass language and integration tests to obtain a single permit.
8. Better protection and integration of migrant workers
Migrant workers will have easier access to clear, multilingual information about their rights and obligations via the revamped ‘Your Future in Flanders’ portal. There will also be better inspection of housing conditions, especially where employers provide accommodation, and a stronger safety net for victims of exploitation. The Flemish government intends that all migrant workers in the future will have to follow integration courses.
Employers will be required to inform employees about their work conditions before the employment starts. Employers who do not carefully manage the employment of migrant workers may be subject to penalties.
9. Digitalisation of migration services
A new IT system called VLAMA will automate a large part of the permit application process by pulling in verified data (e.g. salary records and registration status from Dimona and DMFA, as is already performed by the Economic Migration Service in the Brussels Capital Region). According to the concept note, this should drastically reduce manual work, speed up approvals, and allow for more data-driven fraud detection.
10. A coordinated and evaluated migration strategy
The concept note promises a movement towards a fully-integrated migration approach, combining the work of multiple agencies, in particular with the Federal Immigration Office. Key policy aspects, such as wage thresholds, the role of international welcome centres, and self-employed migration (professional cards), will be regularly reviewed.
Conclusion: Faster, but not easier, and at a cost
While the processing times for single permit applications will be significantly reduced (at least for the work component handled by the Flemish government), this planned reform comes at a cost, both literally and procedurally. For the first time, a fee will be introduced for submitting a single permit application, which, until now, has been free of charge for the work part. Moreover, faster processing does not mean simpler processing. Some examples include: employers applying for medium-skilled professions will face a heavier administrative burden, low-skilled professions will no longer be eligible for single permit applications, and even highly-qualified professions will lose flexibility, as they will only be permitted to work in roles that correspond to their level of education.
Full implementation of the note will likely be rolled-out in the coming months.
Did you know?
ALTIUS can assist you with the handling of applications for single permits, work permits, and professional cards. We can support you throughout the entire process, from strategic advice to complete application management, ensuring compliance with the (tightened) administrative and legal requirements.
If you would like further information or assistance regarding this topic, then please contact Philippe De Wulf ([email protected]) or Emma Van Caenegem ([email protected]).