CBA 19/11 - Better public transport reimbursement from June

Author: Laurence Philippe (Legal Expert)
Read time: 6min
Publication date: 22/04/2024 - 11:20
Latest update: 22/04/2024 - 11:22

Good news for some commuters: the contribution to their public transport season ticket will increase from 1 June! However, they will have to get the right fare formula, and as we will see, that is not so easy. 

Collective bargaining agreement no. 19/9: a minimum obligation

The employer's financial contribution to the cost of the employees’ transport is provided for in collective bargaining agreement (CBA) no. 19/9, concluded in 2019. This CBA establishes the obligation for employers to pay a contribution when their employees use the train and/or other means of public transport for their commuting. It is supplementary, i.e. it establishes a minimum obligation to be complied with.

CBA no. 19/9 established a grid of lump sums that determines the employer’s contribution. This grid applies according to the distance travelled. 

In 2019, these amounts corresponded to 70% of the rail season ticket. In February 2024, after the last indexation of the rail season ticket, this contribution was only 56% of the rail season ticket price. 

This is why the social partners have adopted CBA no. 19/11. 

CBA no. 19/11 - indexation of amounts

CBA no. 19/11, adopted on 8 April, provides for an increase in the employer’s contributions on 1 June 2024. On 1 June, this contribution will be 71.8% of the cost of the rail season ticket. That is 15.8% of the cost of the rail season ticket more to be borne by the employer from now on.

To ensure that future indexation of the rail season ticket does not widen the gap between the employer’s contribution and the cost to employees, an indexation mechanism will be in place until 2029..

From now on, whenever the rail season ticket is adjusted in February, the amounts in CBA no. 19 will also be adjusted. However, the indexation percentage will be limited. The first percentage point of indexation of the rail season ticket will be fully reflected in the employer’s contribution; thereafter, half of the indexation will be reflected and the indexation percentage of the employer’s contribution may not exceed 2.5%.

In summary, this results in the following table.

Indexation of the SNCB/NMBS rail season ticket

Indexation CBA 19 

(Employer’s contribution)















Flex season ticket

With the increase in teleworking, many employees are using the train less regularly for their commuting. A new fare formula - the Flex season ticket - was introduced by SNCB/NMBS in June 2021.

Employees can choose between different formulas:

  • Either the Flex monthly season ticket:
    • 6 days per month
    • 10 days per month
  • Either the Flex annual season ticket:
    • 80 days per year; 
    • 120 days per year.

This season ticket must always be used for the same journey (same departure and arrival station).

The social partners had not yet ruled on the employer’s contribution to be allocated to employees with a Flex season ticket. As of now, CBA no. 19/11 determines the amounts of the employer’s contribution to the flex season ticket for the 4 existing formulas.

Choice of season ticket

In CBA no. 19, there was no mention of the choice of fare formula (monthly, annual, etc.). The new CBA no. 19/11 now stipulates that the employee should "choose the ticket most appropriate to his working regime and, in particular, the number of commuting journeys he is required to make." 

While at first glance this provision seems simple and logical, in practice it is not so evident. A closer look at the different formulas reveals something surprising. For instance, if an employee commutes to work 10 days a month and makes 20 journeys, it is better for him to opt for 2 half-time season tickets instead of the Flex season ticket for 10 days/month. What is even more surprising is that this formula is designed for employees who commute to work 2-3 days a week. 

Let us look at the cost of the rail season ticket for an employee commuting from Ottignies to Brussels (26 km):

  • If he commutes to work 10 days a month, he pays €85 with a half-time season ticket and €88 with the Flex season ticket for 10 days/month. 
  • Even if he chooses the annual formula, he pays €680 for 80 days with the half-time season ticket and €769 with the flex season ticket for 80 days/year. 
  • If he chooses the package of 120 journeys per year, he pays €1,017 with the flex season ticket and €1,020 with the half-time season ticket. So only with this formula is the flex season ticket more advantageous (€3). However, with the half-time season ticket, employees can vary their use even more, as half-time season tickets are valid for 15 days and do not necessarily have to be used consecutively.   

What about the tax credit? 

The tax credit for increasing the employer’s contribution to a rail season ticket applies only to rail season tickets (and not to other public transport season tickets). This tax credit is currently not yet finally approved.

Employers who have to increase their contribution as a result of CBA no. 19/11 will not be able to benefit from this tax credit. In order to benefit from it, a minimum contribution of 79.3% of the cost of the rail season ticket is required (while CBA no. 19/11 provides for a contribution corresponding to 71.8% of this cost). They will therefore have to make an additional effort to qualify for this. We also note that by paying an 80% contribution, the employee can benefit from the third-party payer scheme and be reimbursed 100% of the cost of his season ticket, since the government pays the remaining 20%. In this event, however, the employer cannot benefit from a tax credit. 

Transport costs in my sector

CBA no. 19/11 only regulates the employer’s contribution to the cost of public transport season tickets. However, in some cases this may affect the contribution to the cost of private transport (car). It will be necessary to see what is provided for each sector.

In the sector documentation, you will find detailed information on the amounts to be allocated per joint committee. This documentation sets out the contribution to transport costs for each means of transport used, regardless of whether it is based on CBA no. 19/9, rail season tickets amounts or a sector-specific scale.

Source: CBA no. 19/11 of 8 April 2024 amending CBA no. 19/9 of 23 April 2019 on the employer's financial contribution to the price of employee transport.

The Partena Professional website is a channel for making information available in an understandable form to affiliated members and non-members. Partena Professional strives to provide up-to-date information and this information is compiled with the greatest care (including in the form of Infoflashes). However, as social and fiscal legislation is constantly changing, Partena Professional cannot accept any liability for the correctness, the up-to-date or the completeness of the information consulted or exchanged via this website. Further provisions can be read in our general disclaimer that applies to every consultation of this website. By consulting this website, you expressly accept the provisions of this disclaimer. Partena Professional can unilaterally change the content of this disclaimer.