How the region changes the budget

The first task is to sort the items. Part of the budget follows identical rules in all three regions; the rest changes as soon as a regional boundary is crossed.

Item or rule	Level	Text or framework	Effect on the budget
Involvement of an architect	federal	Act of 20 February 1939, art. 4	fees present in all three regions
Incompatibility between architect and contractor	federal	Act of 20 February 1939, art. 6	design appointment and contracting always separate
Health and safety coordination	federal	Act of 4 August 1996, Royal Decree of 25 January 2001	coordinators required with several contractors, appointed by the client from 500 m²
Ten-year liability insurance (housing where an architect is compulsory)	federal	Act of 31 May 2017	certificate before the works begin
Private works contract	federal	old Civil Code, art. 1787 and following	same rules on lump sums and extras
Public procurement	federal	Act of 17 June 2016 and its decrees	same thresholds and procedures
Permit	regional	CoBAT (Brussels), CoDT (Wallonia), omgevingsvergunning (Flanders)	different timescale, file and cost
Energy performance	regional	PEB (Brussels and Wallonia), EPB (Flanders)	different requirements, adviser and procedure
Planning charges	regional	each region's own regime	different amount and basis
Grants	regional	each region's own regimes	possible income, different conditions
Registration duties	regional	each region's own regimes	different acquisition cost

Federal items are budgeted once. Architect's fees, health and safety coordination, insurance, the rules of the works contract or of public procurement: a maître d'ouvrage (bouwheer, the client) building in two regions applies the same texts, even if market prices differ.

Regional items are budgeted project by project. A budget template drawn up for a Brussels project cannot be transferred to Liège or Ghent without rereading every regional line. It is a common mistake among clients who operate in several regions.

VAT is not a regional matter, but its regime depends on the conditions of the project. It is covered in the guide on prices per m², and no rate is given here.

Three regions, three permit frameworks. In Brussels, the permis d'urbanisme (planning permit) falls under the CoBAT; in Wallonia, under the CoDT; in Flanders, under the omgevingsvergunning (environmental permit). For the budget, the client only needs to retain three effects.

The timescale. The processing time weighs on the budget's value date: the further away the permit is, the more the gap between the dated budget and prices at tender stage is likely to grow, and the longer any finance costs run. The budget must therefore carry an assumed permit date, open to revision.

The file. Each region asks for its own documents and studies, which carry a cost in fees and sometimes in preliminary surveys. They enter the total cost from the permit application stage.

The direct cost. Taxes and fees linked to the application or to the issue of the permit vary by region. Orders of magnitude are covered in the article on permit costs by region; they do not carry over from one region to another.

A permit issued with conditions can change the project, and therefore the works budget. A condition imposed on issue is a change that does not come from the client: it is priced and recorded as such, with an additional agreement stating its financial impact if the brief is affected (code of ethics of the Ordre des architectes, the Order of Architects, of 16 November 2022, art. 16).

Energy changes the budget in two ways: through the cost of the technical solutions it imposes, and through the assignment of a specific adviser. The first effect is covered in the article on energy requirements by region; the second is a client item.

In Wallonia, an approved responsable PEB (energy performance adviser) must be appointed. The regulations rest on the decree of 28 November 2013 and the Walloon Government decree of 15 May 2014. The initial PEB declaration is attached to the permit application and the final declaration follows the works. The item therefore appears from the permit stage and closes after the works.

In Flanders, the bouwheer appoints an EPB-verslaggever (energy performance reporter) before the works begin. This can be an architect or an engineer. Fines are provided for in the event of failure; their amount is not reproduced here. A client who entrusts the assignment to its architect must check that it appears in the agreement and in the fees, failing which it becomes an additional item.

In Brussels, PEB regulations fall under the Brussels Code of Air, Climate and Energy Management (ordinance of 2 May 2013). For a new build or a major renovation, the declarant appoints a conseiller PEB (energy performance adviser), the PEB proposal is attached to the permit application and the PEB declaration follows completion of the works. The budget includes the line from design stage and checks, as in Flanders, whether the assignment appears in the architect's agreement.

Region	Energy framework	Adviser	When the item appears
Brussels-Capital	PEB (COBRACE, ordinance of 2/05/2013)	conseiller PEB appointed by the declarant (new build and major renovation)	PEB proposal with the permit application, PEB declaration after the works
Wallonia	PEB (decree of 28/11/2013, Walloon Government decree of 15/05/2014)	approved responsable PEB	initial declaration with the permit, final declaration after the works
Flanders	EPB	EPB-verslaggever appointed by the bouwheer	at the latest before the works begin

Charges d'urbanisme (planning charges) follow a regime specific to each region, and they are only known with certainty when the permit is issued. They are part of the total project cost, set out in the article From works budget to total project cost.

In the Brussels-Capital Region, the regime rests on a regional government decree of 26 September 2013, published in the Moniteur belge (Belgian Official Gazette) on 2 December 2013 and in force since 21 December 2013, which sets amounts per m² according to use. A 2024 reform has been reported; no amount is given here, and the budget must rely on the version in force on the date of submission, checked for the project. The Brussels framework is presented in the article Brussels: CoBAT regulation and density.

In Wallonia and Flanders, charges may be imposed under each region's own regime (stedenbouwkundige lasten in Flanders). Their rules are not detailed here: they should be confirmed with the authority that issues the permit.

Good practice is common to all three regions: enter the charges as an estimated line, with its source and date, until the permit is issued. The amount from another project is never reused without checking the use, the floor area and the region.

Grants are possible income, not certainties. They depend on regional regimes, conditions and timetables that change. A prudent budget enters them as separate income, never as a deduction from the works, and only once their conditions have been checked. The Walloon framework is presented in the article Wallonia: Q-ZEN, permits and grants, the Flemish framework in Flanders: omgevingsvergunning and renovation duty.

Registration duties are regional. They concern the acquisition of the land or the property, and form part of the total project cost when the acquisition is part of the project. They are not costed here.

Add a "region" column to every line of the budget. For each item, state whether it is federal or regional and, if regional, the text or source that sets its value. A regional line without a source is a line to be checked.

Have the architect confirm, from the agreement onwards, the list of the project's regional obligations. Permit, energy, charges: the project architect knows the procedures of the region where they practise, and the agreement must say who takes on each assignment. It is also the moment to check whether or not the PEB or EPB assignment is included in the fees.

Date every regional line. Regional rules change, sometimes during a project: the Brussels reform of planning charges is one example. The date of checking is part of the value.

Never publish or pass on a ratio without its region. A "Belgian" cost per m² mixes different permit, energy and charges frameworks. For a client comparing projects located in several regions, the comparison only makes sense item by item.