Briefing Document & Podcast: Belgium Mandatory B2B E-Invoicing

Belgium’s E-Invoicing and E-Reporting Mandates

Purpose: This briefing provides a detailed overview of Belgium’s electronic invoicing (e-invoicing) and electronic reporting (e-reporting) mandates, highlighting key timelines, technical requirements, legal frameworks, and implications for businesses.

1. Introduction and Core Objectives

Belgium is undergoing a significant digital transformation of its tax system, driven by a generalized obligation for businesses to issue structured electronic invoices. This initiative is a “first step” towards modernizing VAT data flows between taxpayers and the Federal Public Service Finance (FOD Financiën), aiming to “maximally utilize modern technologies that offer the possibility to digitize, automate, and accelerate those data flows.” (Belgisch Staatsblad).

The overarching objectives of this reform are:

• Combat Tax Evasion and Reduce the “VAT Gap”: The “VAT gap” is the difference between expected and collected VAT revenue. Structured e-invoices are expected to “contribute substantially to reducing the VAT gap and thus to increasing VAT revenues” by minimizing errors through automation and facilitating more efficient compliance and control initiatives. (Belgisch Staatsblad; Belgium’s E-Invoicing Mandate: Compliance and Impact).
• Increase Tax Efficiency: The automation of invoicing processes reduces the likelihood of errors and allows for easier exploitation of data for compliance checks and control by tax authorities. (Belgisch Staatsblad).
• Future-Proofing for Digital Reporting: Structured e-invoicing forms the foundation for future “electronic reporting systems” and “digital ‘near real-time’ reporting obligations.” (Belgisch Staatsblad; Belgium’s E-Invoicing Mandate: Compliance and Impact).
• Promote Business Digitalization: The electronic invoice is seen as a “gateway for business digitalization making them more competitive.” (Belgium’s Electronic Invoicing Mandate for VAT and Income Tax).

2. Key Definitions: “Structured Electronic Invoice”

A “structured electronic invoice” (gestructureerde elektronische factuur) is a central concept in the new Belgian legislation. It is defined as “an electronic invoice that is created, sent, and received in a specific structured electronic format, enabling its automatic and electronic processing by machines.” (Belgium’s E-Invoicing Mandate: Compliance and Impact). This distinguishes it from “normal” electronic invoices, such as PDFs sent via email, which are not machine-readable in a structured way that allows for automated processing without human intervention. (Belgium’s E-Invoicing Mandate: Compliance and Impact).

3. B2B E-Invoicing Mandate (Effective January 1, 2026)

3.1. Scope and Obligation:

• Mandatory Date: “Mandatory structured electronic invoicing for Business-to-Business (B2B) transactions in Belgium will come into effect on January 1, 2026.” (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad). This applies to all VAT-liable operations between VAT-liable entities established in Belgium and registered for VAT purposes. (eInvoicing in Belgium; Belgium’s Electronic Invoicing Mandate for VAT and Income Tax).
• Exemptions (Suppliers): Certain entities are excluded from the e-invoicing obligation, including foreign entities solely registered for VAT in Belgium, Belgian entities conducting certain VAT-exempt activities (under Article 44 of the VAT Code), bankrupt entities, and those under a special flat-rate scheme (to be abolished in 2028). (eInvoicing in Belgium).
• Exemptions (Customers): Certain VAT-exempt entities and foreign taxpayers with a Belgian VAT number but no permanent establishment are exempt from the requirement to receive e-invoices. (eInvoicing in Belgium).
• Transaction Scope: The mandate applies to “all local B2B VAT transactions in Belgium unless exempt under article 44 of the Belgian VAT Code, including supplies under local reverse charge.” (eInvoicing in Belgium). Intra-community supplies and services taxed in another EU country are not included. (eInvoicing in Belgium).
• Paper Invoices/Unstructured Formats: As of January 1, 2026, “Paper invoices and unstructured formats (e.g., PDF) will not be allowed” for mandated transactions. (Belgium: Electronic Invoicing in January 2026 and e-Reporting in January 2028).

3.2. Technical Standards and Interoperability:

• Default Standard: The primary standard is “the Peppol BIS (Business Interoperability Specification) in the UBL (Universal Business Language) version.” (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad). Peppol BIS, while covering all documents in the procurement chain, is specifically used for invoices and related documents (e.g., credit notes) under this mandate. (Belgisch Staatsblad).
• Default Transmission Network: The “default transmission method for these invoices will be the Peppol (Pan-European Public Procurement Online) transmission network.” (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad).
• Interoperability Levels: Full interoperability is ensured through three levels:
  • Semantic Interoperability: “The precise meaning of the information contained within the electronic invoice is preserved and unambiguously understood by all parties, regardless of how it is physically presented or transmitted.” (Belgium’s E-Invoicing Mandate: Compliance and Impact).
  • Syntactic Interoperability: This refers to the “structured electronic format or language used to represent the different data components of an e-invoice, enabling direct exchange and automatic processing by machines.” (Belgium’s E-Invoicing Mandate: Compliance and Impact).
  • Technical Interoperability: This concerns the “actual method of transmission, ensuring that information can be consistently offered and processed between different business systems, irrespective of their underlying technology, application, or platform.” (Belgium’s E-Invoicing Mandate: Compliance and Impact).
• Flexibility and Alternative Formats: While Peppol BIS UBL is the default, “a taxpayer may use a different format and potentially a different digital transmission method if both parties involved in the transaction agree.” (Belgium’s E-Invoicing Mandate: Compliance and Impact). However, “any alternative format must still comply with the European semantic and syntactic standards, specifically EN 16931.” (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad).
• Mandatory Peppol Capabilities: Despite the allowance for alternative formats, businesses “are still required to possess the technical capability to issue and receive structured electronic invoices in the Peppol BIS format, as they cannot unilaterally impose an alternative format on their trading partners.” (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad). This ensures the primary standard remains accessible.

3.3. Peppol Network Advantages: The Peppol network is emphasized for its crucial role in ensuring “seamless, secure, and standardized communication.” Key advantages include:

• Full Interoperability: “an open, uniform, and multilateral network, Peppol ensures that businesses can exchange structured electronic documents with any other participant through a single connection.” (Belgium’s E-Invoicing Mandate: Compliance and Impact).
• Enhanced Security: It provides “strong guarantees for the authenticity of the origin and integrity of the content of structured electronic invoices, protecting against manipulation and unauthorized access.” (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad).
• Correct Standard Application: Accredited “Access Points” validate the correct application of semantic and syntactic standards before transmission. (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad).
• Future-Proofing: “Connecting via Peppol aligns businesses with future national and European digital ‘near real-time’ reporting obligations, as this network is expected to be leveraged for those purposes as well.” (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad).

4. B2G E-Invoicing Mandate (Already in Effect, Phased Approach)

Belgium has had a Business-to-Government (B2G) e-invoicing mandate in place, predating the B2B mandate.

• Legislation: The federal law on public procurement of April 7, 2019, transposes EU Directive 2014/55/EU, requiring public sector administrations to receive and process e-invoices compliant with the European standard (EN 16931). (eInvoicing in Belgium).
• Phased Implementation: A Royal Decree of March 9, 2022, introduced a phased implementation based on contract value:
  • Contracts ≥ EUR 215,000: Mandatory since November 1, 2022.
  • Contracts ≥ EUR 30,000: Mandatory since May 1, 2023.
  • Contracts < EUR 30,000: Mandatory since November 1, 2023.
  • Contracts < EUR 3,000: Exempt. (eInvoicing in Belgium).
• Regional Mandates: Regional governments (Flanders, Brussels-Capital Region, Wallonia) have also implemented their own mandates, with some predating the federal law. (eInvoicing in Belgium).
• Mercurius Platform: The “Mercurius platform serves as the central hub for B2G eInvoicing, fully aligned with the Peppol model.” It offers automated and manual invoice submission and tracking services. (eInvoicing in Belgium; Belgium’s E-Invoicing and E-Reporting Framework).
• Hermes Platform (Temporary): Belgium also developed the Hermes platform as a “temporary solution” to support entities not yet equipped to receive structured e-invoices, converting them to readable formats (e.g., PDF). Hermes is designed to be phased out as digital maturity increases. (eInvoicing in Belgium).

5. E-Reporting Mandate (Expected January 1, 2028)

• Near Real-Time System: Belgium plans to introduce a “mandatory near real-time e-Reporting system for tax purposes, starting on January 1, 2028.” (Belgium: Electronic Invoicing in January 2026 and e-Reporting in January 2028).
• Peppol 5-Corner Model: This system will be “based on a Peppol 5-corner model, allowing secure and standardized communication between businesses and the Belgian tax administration,” where “Peppol Access Points will electronically send specific tax data to a centralized government portal.” (Belgium: Electronic Invoicing in January 2026 and e-Reporting in January 2028).
• Objective: The primary objective is to “optimize tax data collection and combat tax evasion by providing near real-time electronic reporting of commercial transactions.” (Belgium: Electronic Invoicing in January 2026 and e-Reporting in January 2028).
• Replacement: This system is intended to “eventually replace the annual VAT client listing, eliminating complex administrative processes and reducing errors in data collection.” (Belgium: Electronic Invoicing in January 2026 and e-Reporting in January 2028; eInvoicing in Belgium).
• Integration: The transmission system is expected to integrate cash registers and payment and invoicing systems. (Pagero).

6. Impact of the ViDA Directive

The ViDA Directive (VAT in the Digital Age), specifically Directive (EU) 2025/516 of March 11, 2025, is highly significant for Belgium’s e-invoicing legislation.

• Enabling Mandates: This directive “amends previous EU VAT directives, enabling Member States like Belgium to mandate structured electronic invoicing between taxpayers without requiring prior consent from the invoice recipient.” (Belgium’s E-Invoicing and E-Reporting Framework).
• Facilitated Implementation: The ViDA Directive explicitly allows Belgium’s law of February 6, 2024, and the Royal Decree of July 8, 2025, to “enter into force on January 1, 2026, without prior authorization from the Council based on Article 395 of Directive 2006/112/EG.” (Belgisch Staatsblad). Previously, such mandates required specific derogations, which are now no longer needed under the revised Directive.

7. Rounding Rules for VAT Amounts

A change in rounding rules accompanies the new e-invoicing regulations:

• New Rule: For structured electronic invoices complying with European semantic and syntactic standards, “rounding of the VAT amount is now exclusively permitted on the total amount of tax stated on the invoice.” (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad; Pagero).
• Previous Flexibility Removed: Previously, for accounting purposes, rounding per good or service, or per rate, was allowed. This is “no longer applicable to structured electronic invoices,” meaning “rounding per individual line item (per transaction) on a structured electronic invoice is no longer allowed.” (Belgium’s E-Invoicing Mandate: Compliance and Impact).

8. Penalties for Non-Compliance

Failure to comply with the technical capability requirements for issuing and receiving structured electronic invoices carries non-proportional fiscal fines.

• • Penalty Structure:First offense: €1,500
  • Second offense: €3,000
  • Subsequent offenses: €5,000 (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad; Pagero).
• Grace Period for Rectification: To allow businesses to adapt, a subsequent offense will only be considered if “it is detected at least three months after the previous infraction that led to an administrative fine was established by the administration.” (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgisch Staatsblad).

9. Legal and Regulatory Framework

The Belgian e-invoicing framework is based on several key pieces of legislation:

• Law of February 6, 2024: This law introduced the generalized obligation for electronic invoicing. It amended the VAT Code and Income Tax Code 1992. (Belgisch Staatsblad; Belgium’s Electronic Invoicing Mandate for VAT and Income Tax).
• Royal Decree of July 8, 2025: This decree details the implementation of the law of February 6, 2024, by specifying the “standards for semantics, syntax, and method of transmission” that structured electronic invoices must meet as of January 1, 2026. It modifies Royal Decrees Nrs. 1, 8, and 44. (Belgisch Staatsblad).
• European Standard EN 16931: This standard defines the common format and data model for electronic invoices, ensuring machine-readability and compatibility across EU systems. It is “mandatory support of EN 16931 (CIUS Peppol BIS Invoice on Peppol network) for both B2G and B2B mandate.” (eInvoicing in Belgium).
  • Other Royal Decrees Modified:Royal Decree No. 1 (December 29, 1992): Amended to clarify the invoicing obligation towards natural persons for private use, distinguishing it from B2B obligations. (Belgisch Staatsblad).
  • Royal Decree No. 8 (March 12, 1970): Modified regarding VAT rounding rules. (Belgisch Staatsblad).
  • Royal Decree No. 44 (July 9, 2012): Updated to include non-proportional fiscal fines for non-compliance with technical requirements. (Belgisch Staatsblad).

10. Roles and Responsibilities

• Federal Public Service Finance (FOD Financiën): Responsible for overseeing and implementing VAT and income tax regulations. (Belgium’s E-Invoicing Mandate: Compliance and Impact; Belgium’s Electronic Invoicing Mandate for VAT and Income Tax).
• Federal Public Service Policy and Support (FOD BOSA): Acts as the “Belgian Peppol authority” and oversees the management of the Peppol transmission network in Belgium. It also outlines the recognition procedure for Peppol Access Point providers. (Belgisch Staatsblad; Belgium’s E-Invoicing and E-Reporting Framework).
• Access Points (APs): Accredited service providers or entities that enable connection to the Peppol network. They validate the correct application of semantic and syntactic standards before invoices are sent. This decentralized control contrasts with a centralized governmental platform for validation. (Belgisch Staatsblad; Belgium’s E-Invoicing Mandate: Compliance and Impact).
• OpenPeppol: An international non-profit association responsible for the governance and evolution of the Peppol framework.
• Council of State: Provides advisory opinions on draft royal decrees and legislative texts, ensuring legal conformity. (Belgisch Staatsblad).

11. Archiving Requirements

Belgian law specifies requirements for the archiving of invoices:

• Duration: Movable property invoices must be kept for 10 years, immovable property for 15 years, and real estate construction for 25 years. (FAQ on E-Invoicing implementation in Belgium – VATupdate).
• Format: Businesses can archive electronic invoices in the same format as received. It is allowed to convert paper invoices to electronic format for archiving, but conversion from electronic to paper for archiving is generally not permitted if the original was electronic. (FAQ on E-Invoicing implementation in Belgium – VATupdate).
• Authenticity and Integrity: Businesses must ensure the readability, authenticity of origin, and integrity of the content of electronic invoices, particularly given the rapid obsolescence of IT solutions. (FAQ on E-Invoicing implementation in Belgium – VATupdate).
• Cloud Archiving: Cloud computing for archiving is allowed. (FAQ on E-Invoicing implementation in Belgium – VATupdate).
• Third-Party Services: Using intermediary service providers for archiving is permitted. (FAQ on E-Invoicing implementation in Belgium – VATupdate)