Foreign employees officially living in Belgium or with a national registration number will be invited for vaccination according to the normal system. All other foreign employees wishing to receive a vaccine in our country must report to the municipality where they are (temporarily) registered in the civil register. They will then receive a BIS number. Cities and municipalities transfer their list of BIS numbers to the authorised vaccination centres, who invite the foreign workers according to the principles of the vaccination strategy.

The rules applying to Belgians working abroad are somewhat different. A distinction is made between two types of expats. A first group are Belgian expats working or staying abroad, but who still have the Belgian nationality. They are subject to the same rule as other Belgians.

A second group are expats with the Belgian nationality, but who are officially residing abroad. There are two scenarios, depending on whether or not the country where they are officially residing has access to vaccines homologated by the EMA.

1/ If the expats officially living in their country of residence cannot be vaccinated with an EMA-homologated vaccine, then they will be contacted by the Belgian embassy or consulate. Expats who are unknown to these authorities may also contact these services themselves. Those in question will then be given the opportunity to pre-register online for a vaccination in Belgium in the subsequent months, taking into account when they are present in our country. Vaccinations are performed in the military hospital in Neder-Over-Heembeek. Ideally the administered vaccine will be Johnson & Johnson (only 1 injection required).

This procedure applies to the list of countries stated on the Foreign Office website.

2/ Expats who are officially residing abroad and with local access to EMA-homologated vaccines may be vaccinated in the country where they are living. Those in this situation who prefer to be vaccinated in Belgium will be given the chance to register as from July at the earliest. In this case, it is up to them to contact the consulate or embassy.

Those without the Belgian nationality but working for a Belgian company abroad are not entitled to a vaccination in Belgium. They must either be vaccinated in the country where they are employed or in their home country.

The government has established a strict priority list for the vaccination campaign. In the first phase launched in January, the campaign focuses on care home residents and staff, as well as health professionals. They are followed by at-risk groups (phase 1B).

In the second phase, "healthy people" will start to be vaccinated. It is hoped that this phase will begin by June. The goal is to be ready before the summer.

Phasing vaccinations following the advice of the Conseil supérieur de la Santé (Superior Health Council)

  • Phase 1A: care homes (residents and staff), frontline health professionals, hospitals and other healthcare institutions
  • Phase 1B: people aged 65 and over, at-risk patients aged 45-65, key workers
  • Phase 2: Low-risk groups (the rest of the adult population)

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Vaccination will begin in residential care homes and hospitals. Next will be frontline healthcare workers such as general practitioners, home-based carers and dentists. Then residential communities (care for the disabled, day centres, etc.) will become eligible for vaccination.

  • Domestic staff can be vaccinated when it is their turn within the population, depending on their age group, etc. (no specific priority).
  • Trainee staff in residential care homes will be vaccinated.
  • Paramedics and firefighters are not classed as frontline healthcare workers. There is an ongoing discussion as to whether they should be included in Phase 1B as key workers.
  • Occupational health nurses employed by private companies come under phase 1B (after frontline healthcare).
  • First-aid workers will be vaccinated when it is their turn among the general population.
  • The discussion is ongoing regarding where teachers are in the priority list. For the time being, they are not considered a priority group.

Key workers refers to professions that are essential for the health and safety of the population. Subject to change, these consist of the fire brigade, police, civil defence, youth welfare and ambulance services.

It is hoped that it will begin by June. The goal is to be ready by the summer. But it also depends on the supply of vaccines. There may be delays because vaccine production is a complex process, involving living material. Some virus cultures may have to be grown again from scratch.

The vaccine rollout is dependent on the federal immunisation strategy. This determines the priority groups and the order of vaccination as well as general logistics. The production, shipping and transport of vaccines under very strict temperature conditions also influence the speed of the rollout, as does the coordination between federal and regional authorities.

*Delays are always a possibility, as vaccine production is a complex process, involving living material. Some virus cultures may have to be grown again from scratch.

External services for prevention and protection at work are currently in the process of negotiating to play an active role in the process. Offering vaccinations in the workplace would make the large-scale operation more effective. At the same time, it would help to boost take-up of the vaccine among workers.

At Mensura, we are ready to support this initiative and we have the experience to ensure it is carried out efficiently. We also understand the needs of businesses and how companies are organised. Nevertheless, our role in vaccinating the labour force depends on the government’s decision.

Vaccination against coronavirus is voluntary. However, it is important that as many people as possible receive the vaccination. Herd immunity can only be achieved if 70-80% of the population is vaccinated. At this point, enough people will be protected and the virus will no longer be able to spread quickly or widely. Herd immunity is essential in order for normal life to resume without restrictions on social contact. Small spikes in cases will still be possible, but they will no longer result in strict preventive measures or periods of lockdown.

As a precautionary measure, there are specific groups who are not currently eligible for the vaccine:

  • young people under the age of 16;
  • pregnant women. Women who wish to have a child must postpone their pregnancy until at least two months after the last dose of the vaccine. Individual exceptions to this are possible in cases of increased risk (high risk of exposure and/or patient at risk) and subject to a medical certificate from the attending physician;
  • people with a fever who have symptoms that may indicate an acute infection;
  • people who have recently tested positive for coronavirus and had symptoms within the last two weeks;
  • people with a history of severe allergic reactions.

  1. Inform and raise awareness of the vaccine among employees.
  2. Draw up lists of permanent employees and all non-employees (trainees, volunteers, student or casual workers, external workers, etc.).
  3. Set the two vaccination dates in consultation with the prevention service and the coordinating and advising doctor (MCC). Vaccination of staff and residents to take place preferably on the same dates (by the prevention service and MCC respectively).
  4. Order vaccines and make arrangements for delivery on site (separate deliveries are required for each of the two vaccination dates).
  5. Order medical equipment (only one delivery required for both vaccination dates).
  6. Maintain the cold chain and storage of vaccines in approved fridges.
  7. Prepare the room and waiting room before the vaccination day and print planning lists.

Residential care homes that are affiliated with Mensura will receive specific information detailing each of these steps.

Our doctors and nurses have been trained to recognise all the contraindications. They will detect possible contraindications by asking employees an extensive list of questions.

The vaccine cannot worsen the condition of a person who is carrying the virus without showing any symptoms.

Everyone who is vaccinated receives a vaccination card. Each vaccine administered is also registered in VacciNet. This platform is linked to the eHealth platform, where every Belgian citizen has access to his or her own file. You can also print your vaccination certificate from this platform.

No. Vaccination is not compulsory; it is voluntary, regardless of an employee’s role. You cannot impose the vaccine on someone, nor can you require proof of vaccination. This could amount to discrimination. The employer's role is limited to raising awareness of the vaccination programme among its staff.

Any doubts that staff have should be met with understanding and as much information as possible should be provided to them. What side effects are there? Who can (and can’t) be vaccinated? All the latest information can be downloaded from

Measures will not be relaxed until we reach a vaccination rate of 70% of the population.

A vaccination rate of at least 70% is necessary to ensure herd immunity and to prevent outbreaks of infection. The more the vaccination coverage increases, the more flexible the rules can become.

Until then, it is essential that everyone continues to follow the rules, including those who have been vaccinated. While the vaccine protects them from developing the disease, they may still be able to infect others. The capacity of vaccinated people to spread the disease is still being researched.

Research is also ongoing to establish how long the vaccines offer protection for. Repeated jabs may be necessary to maintain a good level of antibodies over the longer term. 

The vaccine is free for everybody. The government is paying for the vaccines and the rollout of the vaccination programme.

It is strongly recommended to do so. As an employer, you are obliged to take measures to prevent the spread of the disease. You can put in place the necessary measures yourself, but it is strongly recommended that you keep the occupational health medical practitioner informed at all times.

The occupational health medical practitioner will be alerted by the tracing centre, the employee themself or the employer. The employee must self-isolate and be tested on days 1 and 7. The test is carried out in a test centre or, in exceptional cases, by the occupational health medical practitioner. The period of self-isolation can end after 10 days.

The occupational health medical practitioner contacts both the employer and the employee to find out about the employee's recent activity and the people with whom they have been in contact at work. Research is carried out into each contact. Any contact for more than 15 minutes at less than 1.5 metres and without a mask is considered a high-risk contact. These high-risk contacts must also begin a period of self-isolation. Low-risk contacts can continue to work, but should be alert to the onset of symptoms.

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In the initial phase of the vaccination campaign, it is recommended that the same procedures should be applied to vaccinated/non-vaccinated persons. Why?

  1. No vaccine offers 100% protection. The risk of infection and disease is much lower, but it still exists. Vaccinated persons with disease symptoms that may indicate COVID-19 still need to be tested (not a rapid test).
  2. There is currently insufficient certainty that persons who have been vaccinated would transmit the virus. As long as vaccination coverage is low in our society, this means that vaccinated persons must still follow the preventive measures and there are no exceptions to quarantining.

Vaccination leave

Vaccination leave is a form of short-term absence. If an employee has a vaccination appointment scheduled during working hours, he/she is entitled to vaccination leave and you are not allowed to refuse it.

If an employee receives a vaccine that needs to be administered twice, and the appointments take place during working hours, he/she must be granted two leaves of absence for vaccination. If the vaccination appointments are outside working hours, the employee is of course not entitled to vaccination leave.

An employee can only take vaccination leave for the time it takes to be vaccinated. Travel to and from the vaccination centre, waiting time and the vaccination itself are included in the time taken for the leave. The exact duration will therefore differ for everyone, but it is not a full day.

No, you must not exert any pressure for the vaccination appointments to be scheduled outside working hours – or at any other time that may be more convenient for your organisation, such as during a leave period.

You may ask the employee for proof. Specifically, you can ask to see proof of the confirmation, time and location of the vaccination appointment.

The employee only needs to show this to you; you are not allowed to keep it. In addition, you may only use the information to calculate the salary and to ensure you have a replacement in place while the employee is absent from work. Keeping a register of who has been vaccinated and who has not is out of the question.

Does the date suggest the employee was called up as a high-risk patient? Then it is absolutely forbidden to make a note or register this on file.

No, you may consider the hours during which the employee is absent as working time. This is suitable, for example, if you are not concerned with the administrative aspect of registering short-term absence.

No, if your employee becomes ill afterwards, the general rules of incapacity for work apply. He/she must then follow the absenteeism procedures in place at your organisation and is entitled to guaranteed pay.