Belgium Requires Filing For Some Business Trips

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 program enacted this week, called Limosa, is causing headaches for some international companies sending employees to Belgium on business.

The Belgian Social Security Administration on April 1 launched a Web site—limosa.be—through which employers can register on behalf of travelers prior to entry into the country. The Web site notes that the employer or organization sending personnel on business to Belgium must make the declaration and that "a third party can also do this on your behalf." The Web 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."

Some corporate travel organizations charged that Limosa has not been well publicized or clearly spelled out, and some travel buyers are readjusting policies to avoid the program's penalties for noncompliance. Fragomen Global Immigration Services in a client alert last month noted that penalties could apply to "both the foreign sending company and the Belgian host company, if any" and could include "imprisonment of the foreign employer for up to two years and a fine of €6205 (approximately US$8,000)."

American Standard Cos. global strategic sourcing director Tom Barrett said he was notified of the policy change last week and is working to ensure travelers are compliant. "I have travelers coming from all parts of the world to that destination," Barrett said. "We've been advised of such regulations and requirements in a very circuitous fashion, and we'd like to have a more seamless process, which we're working on, to comply. We always want to comply, but we're seeking clarification to articulate that to our travelers."

Belgian Social Security officials confirmed this week by e-mail that the new rules apply to business travelers from foreign countries 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 international company in an internal memo noted that employees with a Belgian employment contract—those who "contribute to Belgium Social Security"—also are exempt.