Posting workers to Belgium: which residence rules must be followed?

Workers posted to Belgium, whether EU citizens or non-EEA nationals, are subject to strict residence rules. Many employers mistakenly believe that a residence or work permit issued in another Member State automatically authorises a stay in Belgium. Belgian residence rules are additional and mandatory.

1. Non-EEA workers (third-country nationals)

Short stay (maximum 90 days): presence must be notified to the municipality within 3 working days of arrival (issuance of annex 3 / bijlage 3). Exception: if the worker stays in tourist accommodation subject to guest-registration requirements, the establishment makes the declaration directly.

Long stay (more than 90 days): registration in the foreigners register is mandatory. The decision rests with the Immigration Office (DVZ). Once approved, an A card can be requested.

Fees and timeframes: an administrative fee is required when applying. The registration procedure can take up to 6 months, making it essential to apply immediately after arrival.

2. Workers who are EU citizens

Short stay (maximum 90 days): presence must be declared to the municipality within 10 working days (annex 3ter / bijlage 3ter), except when staying in tourist accommodation.

Long stay (more than 90 days): registration in the foreigners register and issuance of an EU card after approval. All required documents (Limosa, A1, etc.) must be submitted immediately. A provisional document (annex 19) is provided during the procedure.

3. Practical challenges and the impact of the EES (April 2026)

Administrative delays particularly expose non-EEA workers to the risk of temporarily being without a valid residence document when their short stay expires, which may affect the validity of their work permit.

Since the introduction of the Entry/Exit System (EES) on 10 April 2026, issuing annex 3 to non-EEA nationals requires prior instructions from the Immigration Office, unless the worker holds a residence card or a D visa from another Member State.

Conclusion: plan ahead and register your workers as soon as they arrive, with a complete file. SONAS Luxembourg supports you in ensuring that your postings fully comply with the requirements.