EDPBW Explained: 9 Belgian Duties for Employers
Belgium is one of the most structured health and safety jurisdictions in Europe, and foreign parents opening in Brussels or Antwerp routinely underestimate it.
The reason is a two-part system with no British equivalent. Every employer must have an internal prevention service from its first employee. Almost every employer must also affiliate with an approved external service, because the internal one will not hold all the required expertise.
Neither is optional, and the division of work between them is itself a document.
Nine duties, under the Welfare at Work Act of 4 August 1996 and the Code on Well-being at Work.
1. Two services, and you will need both
The structure that determines everything else.
The IDPBW, the internal service for prevention and protection at work, sits inside your organisation. The EDPBW, the external service, is an approved external provider you affiliate with.
The external service exists to carry out the tasks the internal service cannot. Since the internal service of a typical office entity holds none of the specialist disciplines, the practical answer for most foreign-owned entities is that both are required.
The federal employment service publishes the framework for external services.
2. The internal service attaches from the first employee
There is no threshold.
Every employer must set up an internal service with at least one prevention adviser. That obligation begins with the first employee, which is the pattern this series has found across Belgium, Bulgaria, Slovakia and Greece and which surprises British groups accustomed to obligations starting at five.
The internal service assists the employer, the management line and employees in applying the welfare legislation, and contributes to risk analysis, to the analysis of causes of occupational disease and psychosocial risks, and to advice on the organisation of workplaces.
3. Under 20 employees, the employer can be the prevention adviser
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The provision that makes this manageable for a small entity.
Where an employer has fewer than 20 employees, the employer may personally perform the function of prevention adviser.
For a representative office or a small delivery team that is a genuine simplification. It does not remove the obligation to affiliate with an external service, and it does not remove the tasks; it changes who holds the internal role.
4. Five disciplines decide what must go outside
The mechanism that makes affiliation effectively compulsory.
The welfare legislation recognises five specialist disciplines: work safety, occupational medicine, ergonomics, occupational hygiene, and psychosocial aspects.
Where the internal service does not hold specialists in all five, the employer must affiliate with an external service for what is missing. An office entity will not hold an occupational physician or a psychosocial specialist internally, so the answer is affiliation.
Health surveillance is the clearest case: where there is no internal department responsible for medical supervision, the employer must affiliate.
5. Groups A to D change what you must outsource
Belgian employers are classified into groups by size and risk, from A through D.
Group D covers small undertakings with fewer than 20 employees where the employer acts as prevention adviser. Certain tasks in groups C and D must always be carried out by an external service.
The classification therefore determines how much sits inside and how much outside. Establishing which group your entity falls into is the first practical question after hiring.
6. The external service has two distinct sections
Worth knowing, because it explains what you are buying.
The risk management section is multidisciplinary, containing prevention advisers specialising in work safety, occupational medicine, ergonomics, occupational hygiene and psychosocial aspects, and is led by an engineer prevention adviser at level I.
The medical supervision section is led by a prevention adviser who is an occupational physician, supported by nursing and administrative staff.
So affiliation gives access to both risk management expertise and health surveillance, which in most jurisdictions covered in this series are two separate relationships.
7. Visits are prescribed, not negotiated
The obligations on the provider, which are useful to know as a buyer.
The Code requires the external service to visit all affiliated employers regularly. On affiliation, an exploratory company visit takes place under the rules set out in the Code.
That is a meaningful difference from a British consultancy arrangement, where frequency is a commercial matter. Here a minimum level of engagement is prescribed.
8. Information within two months for smaller employers
A specific obligation that benefits newly affiliated entities.
Where an employer's internal service does not have a prevention adviser of at least level II, meaning group D or the lower part of group C, the external service must provide defined information to the newly affiliated employer as soon as possible and within two months of the agreement being concluded, whether or not a visit has yet taken place.
If your entity affiliated recently and received nothing, that is worth raising.
9. The task division is written down, and the advisers are named
Two closing points that make the arrangement auditable.
The division of tasks between internal and external services is recorded in an identification document for the internal service. That document is what an inspector would look at to understand who does what.
And the work is carried out by the same prevention adviser or team. Their names are communicated to the committee and must be displayed somewhere easily accessible to employees, and the external service produces a report for every intervention.
A group that cannot name its Belgian prevention adviser, or cannot produce the identification document, has an affiliation rather than an arrangement.
What a Belgian entity needs
| Duty | Requirement | Common position |
|---|---|---|
| Internal service | From the first employee | Not established |
| Prevention adviser | Named; employer may act below 20 | Assumed unnecessary |
| External affiliation | Where the five disciplines are not held internally | Treated as optional |
| Five disciplines | Determine what is outsourced | Not assessed |
| Group A to D | Determines the split | Unknown |
| Two sections | Risk management and medical supervision | Only one engaged |
| Visits | Exploratory, then regular | Not expected |
| Information duty | Within two months for smaller employers | Never received |
| Identification document | Records the task split | Does not exist |
Rows one and three are the sequence, and row nine is the evidence that the other eight were done properly.
Belgium in the European picture
Belgium sits at the prescriptive end of a range this series has now mapped across Europe.
Britain requires a competent person and leaves the arrangements to the employer. Belgium requires an internal service, a named prevention adviser, affiliation with an approved external provider, a prescribed split across five disciplines, and a document recording it. Slovenia requires a named statutory safety statement and a funded health promotion plan. North Macedonia prescribes the form of its document by rulebook. Bulgaria requires occupational medicine from the first employee and an annual filing.
All implement or align with the same EU Framework Directive 89/391/EEC, and not one is satisfied by another's documents. The Belgian federal service publishes the list of approved external services, and the national knowledge centre Beswic covers the structures.
Holding one group view while each entity meets its own national test is where health and safety consultants and software are worth more together than either alone, and periodic health and safety audits confirm each entity satisfies its own requirements.
Where Arinite fits
Arinite works with locally qualified practitioners in Belgium, so the internal role is properly held, the affiliation is with an approved service, and the task division is documented, while your group keeps one point of contact across every country. We support 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years.
Our health and safety consultants work extensively with finance and banking, legal and IT and software organisations, which account for much of the foreign-owned headcount in Brussels.
Our global health and safety consultants handle the neighbouring jurisdictions that usually accompany a Belgian entity, and our international health and safety consultants can establish what is outstanding locally.
If your Belgian entity has employees and no identification document recording the task split, a free gap analysis is the right place to start.
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Written by
Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
