It's time to get prepared for the mobility survey!

Author: Laurence Philippe (Legal Expert)

Every three years, employers with an average of more than 100 employees are required to analyse the mobility situation in their company. For employers in Brussels, there is a regional obligation in addition to this federal obligation.

The aim of this survey is twofold: to collect reliable statistical data on mobility and to put mobility on the agenda of the social dialogue.

Due to the health crisis, the survey was postponed for a year. The first expiry date is 30 June 2021. However, the social partners agreed that the companies should not carry out the diagnosis until autumn 2021, in the hope that the health situation will return to normal by then.

Employers concerned

The obligation to carry out a mobility diagnosis applies to employers who employ on average more than 100 employees. If the company has several establishments, a diagnosis must be carried out for each establishment with an average of at least 30 employees.

This average is calculated over the 4 quarters preceding 30 June 2021, i.e. from 1 July 2020 to 30 June 2021.

Federal diagnosis

The federal survey is compulsory for all Belgian companies, including those in Brussels.

The questionnaire must be completed electronically. The final form is not yet available, but will be put at your disposal here. You can use your internal data or ask your employees questions using the questionnaire provided. The answers collected are used to automatically fill in the form.

Covid has obliged us to create a new mode of transport: permanent teleworking.

Brussels transport plan

Companies employing more than 100 employees on one site in the Brussels-Capital Region must draw up a company transport plan.

As for the federal diagnosis, the questionnaire must be completed electronically. By completing this Brussels form, you are fulfilling your obligation with respect to the federal diagnosis.

The Environnement Brussels website gives a detailed overview of the procedure to follow. In addition to the mobility diagnosis, employers in Brussels must draw up an action plan. This includes measures to improve mobility and increase the use of sustainable modes of transport. These actions are mandatory.


30 June 2021 is the reference date for carrying out your mobility diagnosis, both at federal level and in Brussels. On this date, you basically determine the number of employees and carry out the diagnosis. However, the social partners agreed with the FPS Mobility that the questionnaire should only be completed in the autumn of 2021. The diagnosis should reflect the situation at the time of data collection.

Subsequently, you must submit the form to the employee representatives for their opinion. The employee representatives then have two months in which to formulate an opinion on this diagnosis. This opinion must be notified together with the diagnosis.

You must submit the form by 31 January 2022.

No later than three months after the plan has been transmitted to the IBGE/BIM, the Brussels companies must inform the employees of the contact person and make the information on the transport plan available to them. 



Programme law of 8 April 2003, articles 161 and following, Belgian Official Gazette of 17.04.2003

Joint opinion of the National Labour Council and the Central Economic Council no. 2.217 of 11 May 2021.

Government Decree of the Brussels-Capital Region of 1 June 2017 on the company transport plans, Belgian Official Gazette of 09.06.2017.

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