Is an employer required to give meal vouchers?

Q: Is an employer required to give meal vouchers?

No. An employer is only required to give meal vouchers if a sector agreement, a company agreement or a written individual agreement provides for them. A right to meal vouchers only arises from a sector agreement, a company agreement or, where there is no union delegation, a written individual agreement (Article 19bis of the royal decree implementing the NSSO act). Without that basis, the vouchers count as ordinary pay. If you grant them, your share is at most € 8.91 per voucher and the employee pays at least € 1.09.

No. An employer is only required to give meal vouchers if a sector agreement, a company agreement or a written individual agreement provides for them.

Last checked on 18 October 2026Read the official text

Is an employer required to give meal vouchers? A Business Centrum case manager at work in the Ghent office

When an employer is required to give meal vouchers

A right to meal vouchers only arises from a sector agreement, a company agreement or, where there is no union delegation, a written individual agreement (Article 19bis of the royal decree implementing the NSSO act). Without that basis, the vouchers count as ordinary pay. If you grant them, your share is at most € 8.91 per voucher and the employee pays at least € 1.09.

Exceptions

A sector agreement can impose them. In construction (JC 124), employers that did not yet give meal vouchers have had to grant them to their blue-collar workers since 1 April 2026. If you already give them under a collective agreement or individual agreement, you keep giving them as long as that arrangement runs.

What is the risk?

Not giving meal vouchers that are due, or giving them late, is a level 3 offence under Article 166 of the Social Criminal Code: an administrative fine of € 1,000 to € 10,000, per employee concerned. Vouchers without a collective agreement or written agreement count as pay, subject to NSSO contributions and withholding tax.

What to do

Check whether your joint committee's collective agreement imposes meal vouchers. If you want to give them voluntarily, record this in a company agreement or, without a union delegation, in a written agreement with each employee.

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Sources

Every amount and deadline on this page was checked against these official sources, last consulted on 18 October 2026.

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