In order to provide a comprehensive view of the issues relating to the application of the ratified Conventions on social security, the Committee considers it appropriate to examine Conventions Nos 102 (minimum standards), 121 (employment injury benefits), 128 (invalidity, old-age and survivors’ benefits), 130 (medical care and sickness benefits) and 168 (employment promotion and protection against unemployment) together.

The Committee notes the observations of the Confederation of Christian Trade Unions (CSC), the General Labour Federation of Belgium (FGTB), and the General Confederation of Liberal Trade Unions of Belgium (CGSLB), received on 23 September 2025, and the Government’s response, received on 24 November 2025.

Part VIII (Maternity benefit). Articles 48(a) and 49 of Convention No. 102. Cost sharing for medical care benefits. The Committee notes the Government’s indication in its report that in the case of pregnancy, the care services provided by midwives, as well as the fees for a doctor-assisted delivery are fully reimbursed by the insurance company. However, the Committee notes that, according to the Government’s information, a standard beneficiary can be asked to contribute €12 for any gynaecological consultation, and that cost-sharing (patient contribution of €34 or €41 for a standard beneficiary) can be claimed for a hospital-based delivery.

The Committee recalls that Article 49 of the Convention provides for medical benefits for pregnancy, delivery and their consequences without cost-sharing of the women protected, which includes both women who are insured and those whose partners are insured. The Committee therefore requests the Government to provide information on the necessary measures taken or envisaged to ensure that prenatal, postnatal and delivery care, as well as hospitalization where necessary, are provided free of charge to women in the case of maternity, whether they are covered by their own insurance or by that of their partner.

Articles 4, 8 and Schedule I of Convention No. 121. The Committee notes the observations of the CSC, the FGTB and the CGSLB which highlight: (i) inadequate protection of domestic workers against occupational diseases; (ii) the limits of the open system to determine occupational diseases; and (iii) the challenges related to the expansion of coverage to platform workers. The Committee requests the Government to provide its comments in this respect.

Article 15 of Convention No. 128. Age of retirement. The Committee notes the Government’s information indicating that the legal retirement age will be raised to 66 years for those who retire between 1 February 2025 and 31 January 2030, and to 67 years for those who retire after this date.

The Committee notes the observations of the CSC, the FGTB and the CGSLB, according to which the increase in the retirement age exceeds the limit of 65 years set by the Convention, which is a compliance problem, except where the country can justify this decision by a higher life expectancy, the financial sustainability of the pension system and the possibility of early retirement without penalty. The CSC, the FGTB and the CGSLB also indicate that, in the current pension reform, the right to early retirement is limited by stricter conditions, a malus is applied for early retirement, even in cases of long-term careers, and there is no automatic exception for arduous occupations.

The Committee notes the Government’s response indicating that the trade union organizations refer to certain aspects of the reform under way, which do not fall under substantive law.

This Committee recalls that, in accordance with Article 15(2) of the Convention, a retirement age of more than 65 years may be fixed by the competent authority with due regard to demographic, economic and social criteria, which shall be demonstrated statistically. The Committee also recalls that, under Article 15(3) of the Convention, if the prescribed retirement age is 65 years or higher, the age shall be lowered, under prescribed conditions, in respect of persons who have been engaged in occupations that are deemed by national legislation, for the purpose of old-age benefit, to be arduous or unhealthy. The Committee requests the Government to provide information on the demographic, economic and social criteria on which the decision to raise the retirement age to more than 65 years was based, including data on healthy life expectancy, disability-free life expectancy, and employment rate among persons older than 65 years in Belgium. The Committee requests the Government to indicate the manner in which it ensures that workers carrying out occupations considered to be arduous or unhealthy by the national legislation benefit from a lower age of retirement.

Article 21 of Convention No. 128. Survivors’ benefits. The Committee notes the observations of the CSC, the FGTB and the CGSLB, according to which the survivors’ benefit has been replaced by a transition allowance that is limited in time (two to four years), which can put survivors in a vulnerable position in the long term. The Committee requests the Government to provide information on this matter.

Article 17 of Convention No. 130. Cost sharing for medical care benefits. The Committee notes the Government’s indication that, on average, the cost-sharing of insured persons in the general insurance scheme and that of self-employed workers for healthcare (2024 data) does not exceed 6.17 per cent of the total of medical benefits. This includes 13.75 per cent for medical consultations and appointments, 9.49 per cent for medication, 2.63 per cent in the case of hospitalization and 10.49 per cent for dental care.

Article 27 of Convention No. 130. Funeral benefit. In its previous comments, the Committee noted that funeral benefits are not granted in the case of the death of a person who was in receipt of sickness benefit. The Committee recalled that in accordance with Article 27(2) of the Convention, a Member State may derogate from the provision of funeral benefits if the conditions set forth in subparagraphs (a), (b) and (c) are also met. Noting the lack of a reply in the Government’s report, the Committee once again requests the Government to provide information on this matter, particularly with regard to subparagraphs (b) and (c) of Article 27(2) of the Convention.

Articles 3 and 16 of Convention No. 168. Amount of unemployment benefits. The Committee notes the observations of the CSC, the FGTB and the CGSLB on the changes in the adaptation of unemployment benefit to well-being of beneficiaries and the lack of consideration given to the position of the social partners in this regard. The Government indicates that the administration is awaiting the conclusions of the social dialogue, which is under way with the Government, and will implement the decisions that result thereof. The Committee requests the Government to provide information in this respect.

Articles 7, 8 and 30 of Convention No. 168. Promotion of productive employment. The CSC, FGTB and CGSLB indicate the absence of effective measures to promote employment in the Brussels-Capital Region, and the presence of financial uncertainty, which lead to the disappearance of many opportunities for jobseekers. In addition, many subsidies generate windfall effects and costs, and there are insufficient scientific analyses of the effectiveness of these measures or, when such analyses are available, they are hardly taken into account. The Committee requests the Government to provide information in this respect.