Mobility budget becomes (partly) mandatory: all your questions answered

What is the mobility budget?

The mobility budget allows employees with a company car (or a position that entitles them to one) to exchange it for a budget that can be used for more sustainable mobility options.

The mobility budget consists of three pillars.

Pillar 1: A more environmentally friendly company car

The employee opts for a vehicle with a lower Total Cost of Ownership (TCO). This essentially means a cheaper car within the available budget. The vehicle must be fully CO₂ emission-free.

Pillar 2: Sustainable alternatives

Examples include public transport, an electric bicycle, or a shared car. Rent or mortgage payments for a home within a 10-kilometer radius of the usual place of work are also possible.

Pillar 3: Cash payment of the remaining budget

The remaining amount is paid out annually. A special employee contribution of 38.07% applies, but the amount is exempt from taxes.

In principle, the mobility budget is cost-neutral for the employer. However, implementation requires careful preparation and administrative follow-up.

For whom does the mobility budget become mandatory?

According to the approved draft, offering a mobility budget will become mandatory:

• From January 1, 2027, for companies with more than 50 employees;

• From January 1, 2028, for companies with 15 to 50 employees;

• Companies with fewer than 15 employees are temporarily exempt.

The obligation only applies to employees who actually have a company car or are entitled to one based on their role.

Employers currently undergoing a collective dismissal procedure with closure, or officially recognized as companies in difficulty, are excluded from the obligation.

How is the mobility budget calculated?

The mobility budget is based on the Total Cost of Ownership (TCO) of the reference company car. This TCO can be calculated either based on actual costs or via a lump-sum formula.

For 2026, the following limits apply:

• Minimum: €3,233.00

• Maximum: €17,244.00

Additionally, the mobility budget may not exceed 20% of the gross annual salary.

A correct and consistent TCO calculation is therefore essential, especially in light of upcoming salary transparency requirements.

Can employees be excluded?

Policies often specify which employees can exchange their company car for a mobility budget, as some roles require a car to perform their duties. According to the draft legislation, employers will no longer be able to completely exclude employees from the mobility budget.

However, employers may require certain employees, if they opt for the mobility budget, to choose a car under Pillar 1. In that case, the employee can use the remaining budget in Pillars 2 or 3.

Note: this obligation may only be imposed based on criteria related to the nature of the role and the legitimate interests of the company. These criteria must be objective, non-discriminatory, and proportionate to the intended objective.

Additionally, employers may wait until the existing lease contract expires before allowing the employee to exchange the car for the mobility budget.

Can all employers introduce a mobility budget?

Yes, provided that the existing entry conditions are met. Currently, an employer must have provided one or more company cars for at least 36 months prior to introduction. According to the draft legislation, this period no longer needs to be continuous.

An exception applies to start-ups that have been active for less than 36 months.

Why take action now?

• The mobility budget will gradually become mandatory;

• The new pay transparency law comes into force in June 2026;

• It is a lever within your ESG and sustainability strategy;

• It helps structurally reduce CO₂ emissions from your fleet;

• It strengthens your employer branding in a competitive labor market.

Companies that proactively analyze, structure, and communicate will avoid time pressure and legal uncertainty once the obligation comes into effect.

Our experts can assist you with:

• impact analysis for your company;

• drafting or revising your mobility/car policy;

• tax and social security optimization;

• practical implementation of the mobility budget.