EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.
The non-recurring result-based bonus scheme, also known as the ‘CLA 90 bonus’, is a collective bonus scheme which is tax-optimized under certain conditions and within certain limits. The bonus is based on a collective bargaining agreement, CLA 90, and can only be granted based on the achievement of collective goals within a predefined reference period.
Although the government had plans to harmonize and to simplify the CLA 90 and profit premium bonus schemes, no legislation has been drafted or voted so far.
In this alert, we highlight the key changes for 2026 and mark the deadlines to keep in mind.
1. Why set up a CLA 90 bonus scheme?
The CLA 90 bonus scheme is a popular benefit in the Belgian market to provide KPI-based bonuses to employees with a more favorable gross-to-net ratio than a regular cash bonus. If we assume a normal bonus is taxable at 53,5% marginal rate (incl. communal tax at 7%), the gross-to-net ratio resulting from a gross bonus amount to roughly 40%. The CLA 90 bonus, however, results in around 87% net compared to gross.
In addition, the bonus is tax-deductible for the company, and no vacation pay is owed on the amount.
CLA 90 is a collective bonus system. Both the objectives and the resulting bonus are collective in nature, meaning the targets must relate to group performance, and the bonus amount is awarded based on the target group rather than being individually determined.
Nevertheless, the CLA 90 scheme offers much flexibility to create an incentivizing bonus scheme that rewards highly performing teams. A bonus plan and target can be determined for specific groups of employees within a company, as long as the target group can be objectively determined, with a group-specific target to match.
Barring sector-level bonus plans, the bonus can be implemented - provided it does not replace existing salary - either through a company-level CLA or (if there is no union representation within the company) via an ‘accession agreement’.
2. Threshold amounts for 2026
The bonus cannot exceed a specific, index-linked maximum amount. The maximum gross amount for social security for 2026 is 4.255 EUR, per calendar year and per employee.
For tax purposes the bonus will be tax-exempt up to a maximum amount of 3.701 EUR in 2026 (after deduction of social security contributions), per calendar year and per employee.
3. NEW: Digital-only submission procedure
A recent proposal of law will change the submissions procedure for the CLA 90 bonus. At time of writing, there are two possibilities:
- A submission procedure via mail (i.e. the company submits all documents on paper);
- A digital submission procedure, with fully digital signatures from the signatories.
The new proposal abolishes the submission procedure via mail. The digital submission procedure would be mandatory. Particularly for companies with international signatories, this may create additional hurdles which should be taken into account when planning the implementation of the bonus plan, given the strict deadlines for implementation.
The initial proposal put the start date of this change on 1 April 2026, which would mean that many bonus plans for 2026 will be affected by this change if passed. Because the legislation is still not final, an amendment is currently pending to change the start date of the change to 1 June 2026.
4. Timeframe implementation
To determine the deadline for implementation of the bonus plan, the reference period must first be determined (e.g. 01.01.2026 until 31.12.2026).
The bonus plan must be finalized and submitted before the end of 1/3rd of the reference period. For plans with a reference period coinciding with the calendar year, the bonus plan must be therefore submitted by Thursday 30 April 2026.
5. Key takeaways
If your organization is considering a bonus plan for calendar year 2026, now is the time to act!
Employers should:
- Review the possibility the grant a bonus under the CLA 90 instead of a regular bonus;
- Make sure to implement the bonus before 30 April if your chosen reference period is calendar year 2026;
- Take into account the digital submission procedure, especially if the signatory of the bonus plan does not have a Belgian eID.
If you want to know more about the CLA 90 bonus and the way to implement this within your company, don’t hesitate to reach out to your EY contact.
Furthermore, our HR Legal professionals are happy to advise you on the legal aspects of your remuneration strategy, the legal compliance of your payroll set-up, the risk of false self-employment, and much more, alongside topics specific to international employment (international social security and labor law). Feel free to reach out to us.