Our webinar on the mobility budget generated a lot of sharp, practical questions from HR professionals and employers. From how TCO is calculated to part-time scenarios, refusal rights, and the three-pillar structure: real-world application raises questions the legal text alone doesn’t always answer clearly.
Below, you’ll find all 15 questions with direct, practical answers.
Important: questions 8 and 10 relate to legislation that has not yet been enacted. We use intentionally hedged language throughout. Wait for the official legal text before adjusting any policies.
1. Is the mobility budget based on gross salary or on the cost of the company car? What happens when an employee moves to a 4/5 regime for parental leave?
The budget is calculated on the basis of the TCO (Total Cost of Ownership) of the company car, the total employer cost (leasing, fuel, insurance, CO₂ solidarity contribution, non-deductible VAT, etc.). The employee’s gross salary only serves as a cap: the budget cannot exceed 1/5 of total annual gross salary, with an absolute maximum of €17,244 for 2026.
When an employee moves to part-time (including parental leave or a 4/5 regime):
- the 20% cap rule remains based on the full-time gross salary, even if the employee works part-time
- if an employee switches to part-time after joining the mobility budget, the budget remains unchanged, unless the part-time arrangement causes the employee to lose their car entitlement under the car policy (in which case the mobility budget ends)
- the same rules apply to employees who were already part-time before joining: car entitlement is the criterion, not the working regime itself
2. If the employee first chooses a company car and then prefers the mobility budget a year later, can the employer refuse?
Yes. The employer is not obliged to accept the request, but must justify the decision on the basis of objective criteria. A refusal without justification is not legally valid.
In practice, the company’s mobility budget policy often specifies that an employee may only submit a request to switch at the end of the current lease period.
3. Does that mean you work with a TCO-based budget?
Yes. Within the mobility budget framework, the employee’s budget is always based on the TCO of the car they are entitled to.
The TCO includes: leasing or rental cost, fuel, insurance, CO₂ solidarity contribution, non-deductible VAT, corporate tax on non-deductible vehicle costs, maintenance, tyres, and miscellaneous costs (charging point, parking, etc.). Any personal contribution by the employee is deducted from the TCO.
4. A car obtained through a salary exchange arrangement is not a company car. Is that correct?
Correct. Only company cars that are not the result of a salary exchange arrangement are eligible for the mobility budget.
5. Is pillar 1 not mandatory to offer?
Correct. Pillar 1 (zero-emission company car) is entirely optional for the employer. Pillar 2 is legally mandatory: the employer must always offer it. Pillar 3 is automatic: if the employee does not use their full mobility budget through pillar 1 and/or pillar 2, the remaining balance is automatically paid out as net cash.
6. With 2 days of remote working, can an employee include housing or rent costs in pillar 2?
The basic rule: any employee who lives within a 10 km radius of their main place of work can use the mobility budget to reimburse their mortgage or rent.
The main place of work is determined each month by counting the number of days worked at each location, specifically the location where the employee was physically present on the most days.
- if the employee works more than 50% remotely (more than 2.5 days per week on average), their home becomes their main place of work. As home is by definition within 10 km of itself, the condition is automatically met.
- with 2 days of remote working out of 5 (40%), the home is not automatically the main place of work; the condition is not guaranteed, and this situation is most likely not eligible
7. How do you determine the budget for fully depreciated company-owned vehicles?
For vehicles purchased directly by the company (not leased), the TCO includes an annual charge equal to the purchase price divided by 5 (depreciation over 5 years). The TCO is therefore not directly linked to the vehicle’s book value.
8. Regarding the headcount threshold for the upcoming mandatory requirement: is it per legal entity? Headcount or FTE? Do flexi-jobs count?
Pending legislation. These questions remain open. We recommend waiting for the official legal text for all clarifications on the counting method, the types of workers included, and the exact scope (legal entity or group). The official legal texts will resolve these ambiguities.
9. What if employees need a vehicle for client visits (e.g. consultants or sales representatives)? Can they be excluded from the mobility budget?
Yes. It is possible to exclude certain categories of employees from the mobility budget policy, particularly when a vehicle is functionally indispensable to their role (e.g. sales representatives who regularly visit clients).
This exclusion must be justified on the basis of objective criteria and applied consistently across comparable roles.
It is also important to clarify how professional travel is treated in the TCO calculation:
- if professional travel is excluded from the TCO, the employer can continue to reimburse those costs separately (e.g. a mileage allowance when the employee uses their private vehicle for client visits)
- if professional travel is included in the TCO, the employee must organise their own client travel within the framework of their mobility budget
10. Can the maximum pillar 2 budget be applied from 1 July 2026, or only from 1 January 2027?
Pending legislation. For now, the current rules continue to apply. Wait for the official legal text before drawing any conclusions about when potential rule changes will take effect.
11. Does the employee need to prove their housing costs, or is a declaration on their honour sufficient?
There is no strict legal obligation as such. However, in the event of a tax inspection or NSSO audit, the employer must be able to demonstrate that the employee is indeed eligible for housing cost reimbursement.
Via the Monizze platform, we ask the employee to provide a copy of their rental agreement or mortgage contract. This ensures the employer has the necessary documentation readily available if an inspection occurs.
12. What is the relationship between pillar 2 and the obligation to offer a social transport subscription for home-to-work travel?
The principle is that the situation before the switch to the mobility budget remains unchanged. Two scenarios apply:
- The employer provided a company car without any additional reimbursement for home-to-work travel: nothing changes with the mobility budget. There is no additional reimbursement for commuting; the employee uses their mobility budget to cover those journeys.
- The employer provided a company car and reimbursed home-to-work travel (e.g. a public transport subscription) for more than 3 months before the switch: both benefits can coexist. The employee continues to receive the mobility budget and their home-to-work travel reimbursement.
13. Can the employee switch back to a company car after 1 or 2 years?
Yes, this is possible. The terms for returning to a company car are defined directly in the company’s mobility budget policy. A return can only happen with the employer’s agreement and within the conditions set by that policy.
14. How does the mobility budget relate to obligations towards blue-collar workers in JC 124?
The obligations under JC 124 (Construction) continue to apply in the usual way. The mobility budget operates in parallel and is solely linked to the conversion of the entitlement to (or provision of) a company car into a mobility budget.
It is important to note that mobility budget legislation (including upcoming amendments) does not apply to home-to-work travel or generalised sector obligations. The two systems are completely separate.
15. An employee chooses the bicycle (pillar 2) for commuting but occasionally uses the employer’s pool vehicle for professional trips. Does the pool vehicle affect the mobility budget?
Two scenarios apply:
- The company makes its vehicle fleet freely available to employees for professional travel: no issue. Both are fully compatible. The cost of the pool vehicle remains with the employer, independently of the mobility budget.
- The company makes its fleet available via an app, at cost to the employee: in that case, the usage cost can be charged directly to the employee’s mobility budget (pillar 2).
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