A European initiative

With the Royal Decree of 19 December 2025, Belgium transposed Directive (EU) 2023/2668 on the protection of workers from the risks related to exposure to asbestos at work. Although the Royal Decree was only published on 30 December 2025, it entered into force retroactively on 22 December, in order to meet the European implementation deadline of 21 December 2025.

To support these new regulations, the European Commission has also published complementary guidelines: Guidelines for managing asbestos-related health and safety risks at work.

What has changed?

The Royal Decree amends various provisions of Book VI of the Code on Well-being at Work. The most important changes include:

  • The occupational exposure limit value for asbestos is to be significantly reduced in successive phases and a new, more efficient measuring technique will be introduced.
  • The obligations regarding the asbestos inventory are tightened.
  • The training and accreditation requirements are enhanced further.
  • Administrative simplification is promoted by making certain templates and forms available on the website of the FPS Employment, Labour and Social Dialogue.
  • A new chapter titled 'Adaptation to the state of the art' is added, thereby enabling faster introduction of new methods when they offer better or equivalent protection of employees.

Drawing up, updating and expanding the asbestos inventory

For most companies, the new obligations relating to the asbestos inventory will be the most noticeable change. Since the Royal Decree entered into force, every employer must maintain an asbestos inventory that accurately records all asbestos-containing materials and all other forms of asbestos present.

The key change is that this inventory must now be updated at least annually through a visual assessment of the condition of the asbestos-containing materials. In addition, an update is required following any event that may affect the state of the materials or upon discovery of asbestos-containing materials not yet included in the inventory.

Furthermore, prior to the start of works that may lead to asbestos exposure, the inventory must be expanded to include information on the presence of asbestos in hard-to-reach parts of buildings, machinery and equipment.

The asbestos inventory must be drawn up and expanded by an accredited asbestos expert.This requirement does not apply for the annual update. The criteria for qualifying as an accredited expert have become more stringent. However, an internal inventory remains possible on condition that the person responsible meets one of the legal categories.

The inventory must follow the template of the FPS Employment. Any existing inventories drawn up before the new rules entered into force remain valid.

A pragmatic approach is adopted: for buildings constructed after 2001, an accurate indication of the year of construction generally suffices to demonstrate that no asbestos-containing materials were used. If no work equipment or objects suspected of containing asbestos are present, no further action is required.

Priority for removal

The new regulations clearly establish that the removal of asbestos-containing materials takes priority. Since the new regulations entered into force, alternative measures, such as sealing or encapsulation, are only permitted under strict conditions:

  • the measures must be temporary.
  • a risk analysis must demonstrate that the measures are at least as safe, if not safer; and
  • the measures must not complicate future removal.

The Directorate-General for Supervision of Well-being at Work has already indicated that it will apply a transition period, during which inspectors will prioritise guidance and education rather than imposing sanctions. Nevertheless, employers are strongly advised to act proactively and draw up and/or expand their asbestos inventory.