Service vouchers: validity limited to December 31 to curb e…

Service vouchers purchased between October 1, 2026, and December 31, 2026, inclusive, will only be valid until December 31, 2026, inclusive, and unused expired vouchers will be automatically refunded to the user. This derogation from the normal regime is established by an order of the Flemish Government dated October 30, 2026, published in the Belgian Official Gazette No. 256 of November 10, 2026, p. 59914-59915, under reference C − 2026/008249.

An Article 11ter reinstated in the 2001 Royal Decree

The mechanism takes the form of an article 11ter reintroduced into the Royal Decree of December 12, 2001, concerning service vouchers — a provision originally inserted by the Royal Decree of January 9, 2004, and repealed by an order of December 18, 2015. The text provides for two distinct derogations:

the validity period provided for in Article 3, § 2, paragraph 1, is set aside: vouchers purchased from October 1, 2026, to December 31, 2026, inclusive, are valid until December 31, 2026, inclusive;
the deadline in Article 7 is also set aside: the approved company shall submit the vouchers purchased during this period to the issuing company no later than February 28, 2027, for payment.

The order takes effect as of October 1, 2026, and is signed by Minister-President M. Diependaele and the Flemish Minister of Education, Justice, and Employment, Z. Demir.

The 2025 “hamstering” argument

The official motivation is explicitly budgetary and behavioral. On September 30, 2026, the Flemish Government decided to reform the service voucher system on January 1, 2027, notably by increasing the purchase price of the vouchers. To prevent users from purchasing massively at the current rate before this date, the executive wanted to make the measure operational starting with October purchases.

The figures cited in the order to support this concern:

25 million additional service vouchers purchased in the year preceding the 2025 price increase;
the number of vouchers purchased beyond the ceiling of 150 vouchers rose from approximately 13.4 million in 2023 to approximately 25.9 million in 2024;
the total number rose from 13.4 million to 25.9 million over the same period.

The text also invokes the need to allow time for the issuing company for technical implementation and communication to users.

An emergency procedure and an opinion from the Council of State

The urgency is evident in the procedure. The legal basis is Article 4, paragraph 1, 1° and 2°, of the Law of July 20, 2001, aimed at promoting the development of local services and employment, replaced by the Law of June 22, 2012. The following formalities have been completed:

agreement of the Flemish Minister in charge of budgetary policy on October 8, 2026;
opinion of the Socio-Economic Council of Flanders (SERV) on October 19, 2026;
opinion no. 80.233/16 of the Council of State on October 26, 2026.

The government justifies the emergency treatment by the fact that a thirty-day period for the request for opinion was insufficient, as the measure concerns purchases already underway since the beginning of the month.

A validity already shortened in September

This temporary limitation is added to a structural tightening. A decree of September 18, 2026 (C − 2026/007183, published in the Belgian Official Gazette of October 7, 2026, p. 53271) reduces the validity period of a service voucher from twelve to nine months and brings forward the deadline for the submission of checks by the approved company from the thirteenth to the eleventh month — two modifications applicable as of January 1, 2027. This same decree includes compliance with the Economic Law Code, including consumer law, among the accreditation conditions for service voucher companies, and excludes from automatic reimbursement the unused vouchers of users who do not have a valid IBAN number with the issuing company. It follows the automatic reimbursement of vouchers expiring as of June 2026.

What this changes in concrete terms

For users, any check purchased as of October 1, 2026 loses its value on December 31, 2026: the useful period is a maximum of three months, compared to nine months for checks under the common law regime starting in 2027. The reimbursement of expired and unused checks is automatic, but the experience of the September mechanism shows that it requires a valid IBAN registered with the issuing company. For approved companies, the submission schedule to the issuing company is pushed back to February 28, 2027, which allows two additional months to process checks from the transitional period. The stated objective remains to ensure that the reform of January 1, 2027 — and the accompanying price increase — effectively produces its effects, whereas the stockpiling of checks had absorbed a significant portion of the volumes in 2024. Anyone who has built up reserves of vouchers must therefore use them before the end of the year or rely on an automatic reimbursement.

Source: Belgian Official Gazette no. 256 of November 10, 2026, p. 59914-59915, C − 2026/008249.