Belgium Requires Advance Reg. For Extended Stays

International business travelers working more than five consecutive days during a single month in Belgium now are required to register with the country prior to entry, the Belgian Ministry of Social Security said. The new program enacted this month, called Limosa, is causing headaches for some international companies sending employees to Belgium and has spurred the Association of Corporate Travel Executives to ask the Belgian government to delay penalties for noncompliance and clarify rules to corporate travel professionals.

The Belgian government on April 1 activated the program, which carries penalties of $8,000 or even imprisonment for noncompliance. ACTE said the program "is causing considerable confusion among travel managers in the U.S. and in Europe—even in Belgium." As such, the association is asking government officials to suspend the program's penalties until May 1 in hopes to "provide enough time to increase awareness of the Limosa program," ACTE executive director Susan Gurley said in a statement. The association last week confirmed Limosa advisor general Karel Deridder and Sarah Scaillet, a representative of the Social Affairs Minister, will address its annual conference next month in Miami.

Meanwhile, ACTE also is concerned about Limosa data privacy issues, as the Belgian government is seeking such information as social security numbers from incoming U.S. citizens.

The Belgian Social Security Administration on April 1 launched the limosa.be Web site through which employers can register on behalf of travelers prior to entry into the country. The site said employers or organizations sending personnel on business to Belgium must make the declaration and that "a third party can also do this on your behalf." The site also notes, "Every applicant shall immediately receive a Limosa-1 certificate of every declaration. The electronic versions of these certificates have to be printed out. Every posted employee, self-employed person or apprentice must be able to produce this Limosa-1 to his Belgian client or principal."

Belgian Social Security officials confirmed that the new rules apply to business travelers from foreign countries, including those in the European Union, working more than five consecutive days, but are exempt as long as trips "do not exceed five consecutive working days per calendar-month." Belgian officials also have set exemptions for government personnel and scientists, among others. One company in an internal memo said employees with a Belgian employment contract—who "contribute to Belgium Social Security"—also are exempt.

The rules remain unclear to many corporate travel professionals. Of 80 travel buyers polled this month by the Business Travel Coalition, only six were aware of the new Belgian policy prior to its implementation. Yet, 43 respondents said the policy impacts their travelers, while 23 respondents weren't yet sure of its impact, highlighting concerns that Limosa has not been well-publicized or clearly spelled out.

The BTC poll showed some travel buyers scrambling to set policies and make travelers aware of the program. A few said they would limit travel to the country to fewer than five days, while many of the respondents said they were working on alerts to send to travelers heading to Belgium. "I will seriously recommend to our travelers that unless it is absolutely critical that they avoid Belgium travel so we don't have to go through this paperwork bureaucracy," one business travel buyer responded.

Another respondent plans to schedule travel to Belgium at the end of the month, taking advantage of Limosa program language stating travelers must only register if the five or more consecutive days of stay occur in a single calendar month.

ACTE said, "A number of ACTE members said they were adjusting travel policies to accommodate the Limosa process, though a small percentage claimed they may shorten business trips to Belgium to less than five consecutive days per month."

American Standard Cos. global strategic sourcing director Tom Barrett is among those travel managers setting policy to drive program compliance. Barrett was notified of the policy change just days before implementation and has been working on alerts to ensure traveler compliance. "I have travelers coming from all parts of the world to that destination," Barrett said. "We've been advised of such requirements in a very circuitous fashion. We'd like a more seamless process, which we're working on, to comply, but we're seeking clarification to articulate that to our travelers."

The Interoperable Delivery of European EGovernment Services said Belgium "voluntarily offers" its Limosa project, the first of its kind, "to the European Commission and the other members states as a basis for a possible pan-European social service."