Flexible corona unemployment after 31.08: application form

Author: Els Poelman (Legal expert)

Companies with at least 20% temporary unemployment in the 2nd quarter of 2020 can continue to benefit from the flexible unemployment force majeure corona, provided they submit an application (see our infoflash of 17 July 2020). The application form is now available on the ONEm/RVA website.

The application form

The application must be made by means of the new form C106A-corona-EPT ( C106A-corona-EPT)

The details of the DmfA performance codes in section III must show that the company had at least 20% temporary unemployment in the second quarter of 2020 and is therefore considered as a "hard hit company (EPT)".

The completed and signed form shall be forwarded to the ONEm/RVA via the e-mail address of the unemployment office responsible for the area of activity of the registered office of the company. The instructions can be found in the form itself.

Registration by the ONEm/RVA

The ONEm/RVA registers the company number (CBE) of the employers whose form C106A-corona-HGO formally complies: correctly filled in and signed, with figures showing that the 20% threshold is reached.

In principle, the ONEm/RVA shall respond to every application within two weeks after it has been sent, so that the employer is informed of the action taken on his application.

Since the ONEm/RVA does not have immediate access to the NSSO data, there is no check on the figures for the second quarter when the form is registered.

Only afterwards will the ONEm/RVA check whether the condition of 20% temporary unemployment has been fulfilled on the basis of the actually submitted DmfA for the second quarter of 2020. Nothing is known about the practical organisation for the time being.

Impact on temporary unemployment from 1 September 2020

C106A-corona-EPT "hard hit company (HGO)" can make use of the simplified force majeure corona procedure after 31 August, and only the employees of these companies are entitled to the corresponding benefit and flexible arrangements.

The ONEm/RVA and the payment bodies will apply this strictly.  A declaration of days of temporary unemployment (Social Risk Declaration scenario 5) with the force majeure corona code will be blocked if the company number of the employer does not appear in the ONEm/RVA database of "hard hit companies (HGO)". The employee will not be entitled to unemployment benefits.

When must the form be submitted?

There is no official application deadline.

BUT: since the registration with the ONEm/RVA must comply with the rules from the very first Social Risk Declaration with force majeure corona (see above), the employer must submit the form as soon as possible.  After all, it is recommended to have confirmation of the registration (the ONEm/RVA responds within two weeks) before continuing the flexible unemployment corona after 31 August.

...in practice

Customers of Partena with temporary unemployment in the second quarter of 2020 will be notified individually via an e-mailing which will also contain information about the provision of figures by the Payroll Consultant.




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