The blacklist of contractors: what does not exist, and what does

No Belgian authority keeps a list of companies judged to be bad, dishonest or unreliable. An administration publishes facts — a registration, a status, a judgment — and a dated fact is not a verdict on the quality of work still to come.

The reason is also a legal one. Naming a company on a list of "bad professionals" without a decision establishing it exposes whoever publishes the list, and a list that got a single line wrong would stay online for years. Domara keeps no list of that kind either, and awards no mark.

What a judge can order, on the other hand, exists and has a precise name: the management ban (interdiction de gérer). It targets a person, not a reputation, and since 2023 it has been entered in a central register.

A management ban is a court decision that deprives a person of the right to hold management office in a company for a fixed period. The FPS Justice brings them together in a central register, which can be consulted online through the JustBan application, on the Just-on-web portal.

Consultation by a citizen has been open since October 2023 for the bans imposed under criminal law, and since June 2024 for civil bans, those that penalise a fault committed in the context of a bankruptcy. It requires identification by eID or itsme, and the search is made by surname, first name and date of birth, by name and address, or by enterprise number.

That is where the difference from a blacklist shows. The register answers a question asked about a person or a number you already know; it cannot be browsed, it cannot be downloaded, and the answer shown to the public is limited to the name and to the start and end dates of the ban, without the grounds.

The public search of the KBO/BCE gives, for an enterprise number, the public data of the entity whatever its status — active, published or ceased — together with its establishment units. The status, the legal situation and the dates that go with them are the only adverse elements a register produces, and they describe an administrative situation, never a behaviour.

Insolvency proceedings are published court decisions, described in the guide devoted to insolvency; the validity of a VAT number is checked against VIES, with the qualifications set out in the guide devoted to it. These three sources cross-reference through the enterprise number, and that is all they have in common.

What none of them records: a botched job, a deadline not kept, a quote that has doubled, a dispute under way. A commercial disagreement leaves no public trace as long as a court has not decided it, and that is precisely the void that forum lists claim to fill.

The pattern is a familiar one: a company stops or goes bankrupt, and the activity starts again a few months later under another company, often at the same address and with the same declared trade. In itself that is neither unlawful nor rare — a bankruptcy does not prohibit going into business again, and many fresh starts are perfectly honest.

What the registers make visible are the dates. An entity created recently carries a recent start date; the entity that has ceased carries its own. Comparing the start date of the enterprise number shown on a quote with the length of standing the company advertises is a reading of the register, not an accusation, and the answer may be excellent.

The only thing that turns this pattern into a prohibition is a judgment — and that is where the register of management bans crosses with the KBO/BCE, since it too can be searched by enterprise number. In the absence of such a decision, dates close together prove nothing about the people: they justify a question asked before signing, and nothing more.

The FPS Economy invites people to report the facts to the Economic Inspectorate through the ConsumerConnect site, so as to keep other people from being caught out. It is a feeding back of information: it supplies market surveillance and can trigger a sectoral investigation, without being a refund procedure.

For a personal file, the same FPS is explicit: lodging a complaint with the local police is the only way for an individual investigation to be opened. The two steps do not exclude one another and do not pursue the same aim, one looking at the market and the other at your file.

Neither of them produces a public list, and that is consistent: a report is an allegation as long as a decision has not established it. A list circulating on a forum reverses exactly that order — with no date, no source, no distinction between two companies with the same name, it names people on the strength of a story, which is defamatory when it is false and unusable when it is true.