E-Invoicing in Belgium: Scope, Regulations & Future Outlook

Legal and Regulatory Framework in Belgium

B2G E-Invoicing Mandate (Business-to-Government)

• Phased Roll-out (2017–2023): The requirement started at regional levels and expanded nationally. The region of Flanders led in 2017, mandating e-invoices for its contracts. The Brussels-Capital region followed in 2020, accepting only e-invoices for its public contracts. By 1 January 2022, Wallonia also made e-invoices the default for B2G transactions (PDF/Word invoices no longer accepted there). A federal Royal Decree on 9 March 2022 established a nationwide phase-in by contract size: [ec.europa.eu]
  • ≥ €215,000: e-invoices required for contracts published from 1 November 2022 [ec.europa.eu]
  • ≥ €30,000: e-invoices required for contracts from 1 May 2023 [ec.europa.eu]
  • < €30,000: e-invoices required for contracts from 1 November 2023 [ec.europa.eu]
  • < €3,000: exempt from mandate (micro-value contracts can still use traditional invoicing).
    By November 2023, all suppliers to the Belgian public sector (for contracts ≥ €3,000) were obliged to invoice electronically. This progressive approach gave businesses time to adapt based on contract scale. [ec.europa.eu]
• Current Rule (since 2024): As of March 2024, electronic invoicing is compulsory for any new public procurement contract in Belgium. In practice, this means all government tenders published after 1 March 2024 must include e-invoicing in their terms. (The €3,000 threshold generally applies, though federal authorities now also require e-invoices even below €3,000 by including that clause in contracts.) Public entities typically use the Mercurius platform – a central hub aligned with Peppol – to receive supplier e-invoices either via automation or manual upload. [einvoice.belgium.be] [ec.europa.eu]
• Legal Basis: The mandate is underpinned by the Public Procurement Law of 7 April 2019, which required agencies to accept EN 16931-compliant invoices, and the Royal Decree of 9 March 2022 which set the above phased obligations. These laws ensure that **all contracting authorities in Belgium can receive and process standard e-invoices, and that suppliers gradually became legally required to send e-invoices in public procurement. [ec.europa.eu]

B2B E-Invoicing Mandate (Business-to-Business)

• Legal Adoption: A law modifying the VAT Code was published in the Belgian Official Journal on 20 Feb 2024 to introduce mandatory B2B e-invoicing. This law takes effect on 1 January 2026, subject to approval by the EU (Belgium applied for a required EU derogation in Oct 2023). Parliament has approved this mandate, making structured electronic invoicing compulsory for nearly all B2B transactions between Belgian VAT-registered entities as of 2026. [vatcalc.com] [einvoice.belgium.be], [ec.europa.eu]
• Scope of Mandate: The obligation covers “all VAT liable operations between VAT-liable entities” in Belgium. In practical terms, any invoice between two businesses or professionals where both have Belgian VAT registration must be issued electronically in a structured format starting 2026. This includes Belgian-established companies and Belgian fixed establishments of foreign companies. B2C invoices (to private consumers) are explicitly excluded – they remain allowed on paper or PDF since the law only targets transactions where both parties are VAT-registered businesses. [ec.europa.eu] [vatcalc.com], [ec.europa.eu] [vatcalc.com], [vatcalc.com] [einvoice.belgium.be], [vatcalc.com]
• Domestic Focus: Cross-border B2B invoices are not directly mandated by the Belgian law. If either the seller or buyer is located outside Belgium (or a foreign company without a Belgian establishment), the e-invoicing requirement does not automatically apply. In such cases, electronic invoicing can still be used on a voluntary basis, but the foreign trading partner must agree to receive e-invoices (otherwise, traditional invoicing can continue). For instance, a Belgian company invoicing a French client will follow the mandate only if France (or EU law) requires it; under Belgian rules alone, that invoice is outside the mandate’s strict scope. Non-resident companies that are merely VAT-registered in Belgium (without a fixed establishment) are currently excluded from the 2026 mandate as issuers or receivers, ensuring the rule targets primarily domestic transactions. [vatcalc.com]
• No Tax Clearance – Exchange Model: Unlike some countries that require every B2B invoice to be reported to or cleared by the tax administration in real-time, Belgium’s 2026 B2B e-invoicing is a decentralised “4-corner” exchange model. Businesses send invoices directly to their trading partners (via approved digital channels) without sending them to the tax authority first. There is no obligation to transmit invoice data to the Belgian VAT authorities at issuance. In other words, the government does not receive or approve each invoice in real-time under this mandate, which differentiates it from “clearance” systems like those in Italy or Mexico. Companies simply must use an electronic format and network for B2B invoices, but keep their normal VAT reporting routines (periodic VAT returns, annual customer listings, etc.) for now. [vatcalc.com] [einvoice.belgium.be], [vatcalc.com]
• Compliance and Penalties: To enforce compliance, Belgium is introducing a penalty regime once the mandate kicks in. Draft guidelines indicate fines of €1,500 for a first offense, €3,000 for a second, and €5,000 for a third offense within 3 months for not complying with e-invoicing/reporting rules. However, authorities also recognize the challenge of transitioning. Recent official FAQs suggest a “grace period” in early 2026: regulators plan no penalties in the first 3 months (possibly up to 6 months) of 2026 for companies making genuine efforts to comply. Additionally, during this transition window, paper/PDF invoices might still be tolerated without requiring retroactive re-issuance as e-invoices. This leniency is to ensure businesses aren’t unduly penalized as they finalize their e-invoicing setups. By mid-2026, though, all businesses are expected to be fully compliant, as PDF invoices will no longer count as valid for B2B transactions after 2025. [vatcalc.com] [vatcalc.com], [Update on…ium Slides] [Update on…ium Slides]
• Key Exceptions: B2C remains outside scope (businesses can continue to issue consumer invoices on paper or via existing methods). Also, certain very small or edge cases may be exempt or handled via simplified solutions (for example, invoices under €3, not just €3,000, might not even be required by VAT law at all). But broadly, from 2026 every taxable B2B transaction in Belgium that currently requires an invoice must use an electronic invoice. [einvoice.belgium.be]

Technical Standards and Infrastructure (PEPPOL & EN 16931)

• European Standard EN 16931: All e-invoices must conform to the EN 16931 standard for electronic invoicing. This is the common semantic data model adopted across the EU, ensuring a consistent structure and required fields (e.g. seller details, buyer details, VAT breakdown, etc.). Belgium explicitly requires structured invoices that meet EN 16931’s syntax and semantic rules for both B2G and B2B transactions. In practice, this means invoices are issued in a machine-readable XML format containing standardized data fields (as opposed to just PDF images of invoices). The default format is the Peppol BIS Billing 3.0 UBL (Universal Business Language XML), which is fully EN 16931-compliant. [ec.europa.eu] [vatcalc.com], [ec.europa.eu]
• PEPPOL Network (4-Corner Model): Belgium has opted for the PEPPOL interoperability framework as the backbone for e-invoicing exchange. PEPPOL (Pan-European Public Procurement Online) is a network governed by a set of standards that allows businesses to exchange electronic documents (like invoices) through accredited Access Point (AP) providers. In the “4-corner” model, the sender and receiver each connect to a service provider (their Access Points), which then transmit the invoice across the network to the recipient’s AP. This model is already used for B2G invoice submission in Belgium (via the Mercurius portal, which itself is a Peppol access point for the public sector) and will be the default for B2B as well. Key technical features: [ec.europa.eu] [vatcalc.com], [vatcalc.com]
  • Addressing: Companies sending e-invoices must identify recipients by a unique identifier. In Belgium’s case, the Enterprise Number/VAT number serves as a primary identifier within Peppol (often formatted as a PEPPOL ID). Belgian authorities strongly encourage using the official enterprise/VAT number to avoid identification issues across systems. [Belgium E-…y April 25]
  • Access Points: Businesses can choose a certified Peppol Access Point provider (or set up their own, if authorized). The Belgian Peppol Authority (federaal BOSA) accredits AP providers to ensure they meet security and interoperability standards. These providers handle the sending and receiving of invoices into the network. Belgium holds AP provider forums every 6–8 weeks to maintain compliance and address issues. [storecove.com]
  • Transmission Protocol: Peppol uses standard transport protocols (AS4/HTTPS) and a lookup service (SML/SMP) to route invoices to the correct recipient’s AP. For end-users, this is behind the scenes; they just send the invoice to their AP, which finds the buyer’s AP. [Belgium E-invoicing]
  • Security & Authenticity: In line with EU requirements, Belgium’s system ensures authenticity of origin and integrity of content for e-invoices. Digital signatures or secure transmission fulfill this – e-invoices must either be sent through the secure network or carry an e-signature to be compliant. This guarantees that invoices aren’t tampered with and truly come from the stated sender. [vatcalc.com] [storecove.com]
  • No Additional National Format: Belgium does not impose a proprietary format or extra fields beyond the EU standard. It uses the Peppol BIS “CIUS” (Core Invoice Usage Specification) without any unique national extension. This means a standard Peppol invoice should suffice, simplifying things for businesses already using e-invoicing in other EU countries. [ec.europa.eu], [ec.europa.eu]
  • Alternate Channels: While Peppol is the main rail, the law allows trading parties to use other e-invoicing solutions by mutual agreement, as long as they comply with EN 16931. For example, two companies could exchange EDIFACT or other XML invoices over a direct EDI link if they prefer – but this is only permissible if both parties agree and the data format meets the required standard. In all cases, unstructured formats like PDF will no longer count as “electronic invoicing” after the mandate kicks in. [vatcalc.com]
• Mercurius Platform (for B2G): The Belgian government operates Mercurius, a centrally managed platform integrated with Peppol for public-sector invoicing. Mercurius acts as an access point and a tracking hub: suppliers can send e-invoices to any public entity via Mercurius, and it provides delivery confirmations and status tracking. It supports both automated submission (from a company’s system via Peppol) and manual input/upload via a web portal, which helps small suppliers who might not have their own AP connection. Mercurius ensures all government bodies receive invoices in the standard format and monitors compliance across the public sector. For B2B, no single central platform exists (being a decentralized model), but many companies will use similar service providers to connect to the Peppol network. [ec.europa.eu]
• Support for Businesses: Belgium’s approach is relatively technology-neutral within the bounds of the standard. Businesses can fulfill the mandate by:
  • Using an ERP system or accounting software updated to output EN 16931-compliant invoices (many modern systems offer a Peppol e-invoicing module or add-on).
  • Connecting to a third-party e-invoicing service (like a Peppol Access Point provider or a VAN/EDI provider) that will take the invoice data from the business, convert it into the required format, and deliver it to the buyer via Peppol. Dozens of such providers are active in Belgium, certified by BOSA. [storecove.com], [storecove.com]
  • Using the Mercurius portal or other web portals for cases with low invoice volume – e.g., manually creating an invoice online which is then sent as Peppol. This is more relevant for B2G or small enterprises.
• Technical Standards Summary: In essence, Belgium’s e-invoices = EN 16931 standard data, transmitted via Peppol. The Peppol BIS 3.0 UBL format is the primary implementation. This format is built on ISO/IEC 19845 (UBL 2.1) and aligns with ISO 20022 financial data standards to ensure international compatibility. The reliance on Peppol means Belgian companies will be using the same network that is now common in many EU countries (especially for B2G), smoothing cross-border interoperability. [vatcalc.com] [storecove.com]

Implementation Timeline and Key Milestones

Future Plans and EU VAT Reform Context

• EU’s Push for E-Invoicing: The European Commission and Council are moving to make electronic invoicing the default across the EU. Under current EU law, member states required special permission (a derogation) to mandate B2B e-invoicing. This will change: the ViDA proposals envision removing this requirement and updating the VAT Directive so that structured e-invoicing can be implemented by any member state freely (which aligns with Belgium’s approach). In fact, from 2024, the EU has already allowed that businesses can send e-invoices without buyer’s prior acceptance (making e-invoices equivalent to paper by default) – a step to encourage adoption. Belgium’s 2026 mandate is consistent with these developments, and Belgium’s request for a derogation is expected to be granted as a formality. [vatcalc.com]
• Digital Reporting Requirements (DRR): A major component of the EU reforms is the introduction of Digital Reporting Requirements for VAT. This means that transaction data will be reported to tax authorities in (near) real-time, replacing summary declarations like EC Sales Lists. For intra-EU (cross-border) B2B supplies, the EU plans to require sellers to submit invoice data to their tax administration within a short period (e.g. 2 days) of issuance, likely via an automated system leveraging e-invoices. Initially, the Commission proposed 2028 for mandating this intra-EU e-reporting, but negotiations point to an implementation by 2030. Once in effect, any Belgian business selling to another EU country will need to ensure its invoices are electronic and that the data is sent to FPS Finance (the Belgian tax authority) promptly. This effectively mandates e-invoicing for cross-border transactions EU-wide, because the easiest way to meet the reporting requirement is to issue a compliant e-invoice. [vatcalc.com]
• Belgium’s 2028 E-Reporting Plan: In anticipation of the EU requirement, Belgium has announced it will introduce its own e-reporting for domestic transactions by 1 January 2028. This will likely require that a copy of each B2B invoice (or key invoice data) is transmitted to the tax authorities around the time of issuance – moving to a continuous transaction control model in practice, albeit using the Peppol infrastructure. According to the Belgian plan: [vatcalc.com]
  • The e-reporting will “replace the annual customer listing” (annual VAT sales list) by giving the tax authority immediate visibility of sales invoices. [vatcalc.com]
  • Belgium will upgrade to a “Peppol 5-corner model”, meaning the Peppol network flow will include routing the invoice data to the government as a fifth participant. This is conceptually similar to how Italy’s SDI works, but Belgium might implement it in a decentralized way using Peppol standards (often called “Peppol BIS Billing 3.0 + extensions” for tax). [vatcalc.com]
  • No extra burden on businesses beyond what e-invoicing requires – companies will still send the invoice via Peppol; the infrastructure will ensure the government gets the data in parallel. The use of service providers or adapted ERPs will continue, so it’s not a separate manual report, it will be automated. [vatcalc.com]
  • The aim is to reduce Belgium’s VAT gap (estimated around €4.8 billion annually) by catching inconsistencies and fraud sooner. [vatcalc.com]
• EU Standardization & Timeline: The EU is working on standardized formats and systems for e-invoicing and reporting to ensure interoperability. Belgium is actively aligning with this: using EN 16931 now ensures compatibility with whatever EU-wide system emerges. The EU’s Council has recently agreed to push the start of mandatory intra-EU e-invoicing to 2028 or 2030 (with full adoption by 2030). Additionally, by 2030–2032 the EU may make digital reporting compulsory for domestic transactions as well (the timeline is under discussion). Belgium’s 2026 and 2028 moves essentially pre-implement these EU reforms on a national level. If EU rules come later, Belgium will already be in compliance or can easily adjust. [vatcalc.com]
• Cross-Border Interoperability: Because Belgium uses Peppol and EN 16931, Belgian e-invoices can be readily transmitted across borders. Many EU countries accept Peppol invoices in B2G contexts, and countries like France (from 2024/2026) and Poland (2024) are also mandating e-invoices albeit with different platforms. The EU is keen on interoperability between national systems. One initiative is an “EUROPE e-invoicing standard network” that Peppol is part of. Belgium is participating in these discussions, meaning Belgian businesses should eventually be able to send one standard e-invoice that satisfies obligations in multiple countries. [vatcalc.com]
• Long-Term Vision: The vision for the future is that paper invoices become extinct for business transactions and VAT reporting becomes immediate and electronic across Europe. Belgium expects this will “lead to a breakthrough in the digitalization of the economy and society”. By 2030+, e-invoicing will be the norm for B2B and cross-border, and possibly by mid-2030s it could extend to B2C if digital receipts become common. Belgium’s current laws do not mandate B2C e-invoicing, but the infrastructure being built could accommodate consumer e-invoices in the future (for example, sending electronic receipts to a digital wallet). [ec.europa.eu] [einvoice.belgium.be], [ec.europa.eu]

Impacts on Cross-Border Transactions and Tax Compliance

• Cross-Border Invoicing (EU): Under Belgian law, if a Belgian company invoices a foreign business (or vice versa), the transaction isn’t compelled to use e-invoicing unless foreign regulations require it. However, companies won’t want to maintain two separate invoicing processes for domestic vs international. Many will choose to extend e-invoicing to cross-border clients/suppliers on a voluntary basis, for efficiency and future-proofing. Notably, Peppol is international – a Belgian firm can send a Peppol invoice to, say, a Dutch customer if the customer is on the network. This can streamline cross-border trade, even before it’s mandated. Businesses should ensure they have the capability to send/receive e-invoices to/from foreign partners, and handle scenarios where a trading partner isn’t ready (perhaps provide them with PDFs if they insist, as currently allowed by EU rules with mutual consent). [vatcalc.com]
• EU VAT and Intra-Community Supplies: For VAT compliance on intra-Community supplies (sales to VAT-registered buyers in other EU countries), currently suppliers must issue an invoice (paper or electronic) and later file an EC Sales Listing. Once the EU’s digital reporting kicks in (~2030), those invoices will need to be electronic and reported almost immediately. Companies operating in Belgium should plan their systems with this in mind. Adopting e-invoicing now provides a head start: the invoice data can eventually be forwarded to meet EU reporting. Also, using EN 16931 standard invoices will simplify compliance with varying local rules (content that meets this standard suffices for VAT in any EU country’s requirements). [vatcalc.com]
• Non-EU Trade: E-invoicing mandates typically cover domestic and intra-EU transactions; invoices for exports or imports (where one party is outside EU) aren’t directly under these rules. Belgium’s law doesn’t force e-invoices for exports to, say, the US or China. However, it’s conceivable that over time, major trading partners might adopt similar frameworks. Already, countries like Turkey and countries in Latin America require e-invoices for exports. Multinationals will benefit from a globally standardized invoicing process. Using Peppol/EN16931 internally could become part of global compliance strategy, even if converting to other formats for specific countries is needed.
• VAT Compliance and Audits: Tax compliance stands to improve with e-invoicing:
  • Data accuracy: Electronic invoices reduce human errors (like typos in amounts or VAT rates) since they can be validated automatically. They also ensure mandatory fields are present (an e-invoice schema can enforce inclusion of VAT number, invoice date, etc.), reducing the chance of non-compliant invoices that jeopardize VAT deductions or require corrections.
  • VAT filing: In the short term (pre-2028), companies still file periodic VAT returns. With e-invoicing, internal VAT reconciliation becomes easier – businesses can more readily match sales and purchase invoices to their VAT ledger, because data is standardized and often integrated with their accounting software. This can speed up VAT return preparation and improve accuracy. In the longer term, when e-reporting starts, a lot of data entry for VAT will be automated.
  • Audit trail: E-invoices must be stored electronically, and their integrity must be guaranteed. Belgium already requires maintaining records of all sent/received e-invoices. For audits, electronic records can be searched and cross-checked efficiently. Tax auditors will likely use the data from e-reporting to pre-audit companies (analysing discrepancies) before requesting information. This means companies need strong internal controls to ensure the e-invoice data they send out (and receive) is correct – mistakes will be visible to authorities immediately. Finance teams should implement validation checks (for example, verifying the VAT identification of customers, verifying invoice numbering continuity, etc., within the e-invoicing system). [storecove.com]
  • VAT deduction: One common concern – can a business deduct input VAT if the supplier didn’t send an e-invoice? During the transition, authorities have clarified that as long as both parties act in good faith, VAT deductions won’t be denied solely due to invoice format issues. But once the mandate is mature, a buyer might be expected to demand an e-invoice from suppliers to deduct VAT. Companies should thus encourage all their local suppliers to comply. Conversely, accounts payable teams should be ready to receive invoices electronically; if a supplier keeps sending paper, the buyer might need to nudge them or potentially even self-billing as e-invoice to stay compliant. After 2026, tax authorities could consider a paper invoice to a Belgian buyer as not a valid invoice (since the supplier broke the rule), which could complicate VAT reclaim. Thus, compliance on both sides of a transaction becomes important. [Update on…ium Slides]
• Multi-VAT and Entity Complexity: Multinational enterprises often have multiple VAT registrations or entity codes. A challenge noted in industry discussions is managing multiple identifiers – e.g., a company with several Belgian VAT numbers will have to ensure each one has its own e-invoicing identity (Peppol ID) and routes invoices correctly. Coordination is needed so that, for example, if Company X has two divisions each with a VAT, invoices aren’t misrouted. Using the official enterprise number as part of the addressing scheme is essential to avoid confusion. This is a compliance detail that tax teams must oversee, ensuring that master data for all entities is correct and consistent. [Belgium E-…y April 25]
• Archiving and Retention: Belgium’s existing rules for invoice retention (typically 7 years for VAT) still apply, but in electronic form. Companies must ensure their e-invoices are stored in a way that guarantees readability over time, integrity, and accessibility to tax authorities upon request. Many e-invoicing service providers include compliant e-archiving solutions, or companies can use their own archiving systems. In any case, tax compliance includes verifying that the e-invoices can be reproduced in a human-readable format (e.g., PDF rendering of the XML) and that an auditor can rely on their authenticity (digital signatures or system logs to prove no alteration).
• Overall Tax Control: E-invoicing together with e-reporting will give the tax authority near real-time oversight of business transactions. Multinationals should anticipate a shift from post-audit to continuous audit by authorities. Instead of periodic VAT audits years later, discrepancies may be flagged quarterly or monthly from the data. This means internal tax compliance teams must adopt more proactive monitoring:
  • Check that sales listed in VAT returns match the sum of e-invoices sent (since the tax office will likely do the same from reported data).
  • Use analytics to detect if any invoice failed to transmit or was rejected by the system.
  • Ensure that any needed corrections (credit notes, cancellations) are done via proper electronic documents referencing the original invoice (as required by the standard).
  • Keep an eye on cross-border reporting: initially still using EC Sales List, but eventually through the system.

Integration with ERP Systems and Implementation Challenges

• ERP System Upgrades: Companies must ensure their ERP or billing software can produce and ingest the required e-invoice format. Many large businesses use ERPs (SAP, Oracle, Microsoft Dynamics, etc.) which may require additional modules or middleware to generate UBL XML invoices. A typical approach is to work with an e-invoicing solution provider that integrates with the ERP: the ERP hands over invoice data (through an API or file export), and the solution maps it to the EN 16931 fields and sends it via Peppol. For inbound invoices, the provider can convert received XML into a format the ERP can import (or even directly post it in accounts payable). Integration points to consider:
  • Data Mapping: All necessary invoice information must be present in the ERP data model. A project in Belgium found it essential to clean up and enrich customer master data before go-live – e.g., making sure every customer record has a valid VAT/enterprise number (for addressing), correct address details, and email (for fallback communications). Similarly, product/service codes, tax codes, etc., in ERP must align with what the e-invoice will show. Any custom fields or country-specific invoice content need mapping to the standard format or a determination if they are optional/omittable. [Learnings…ct Belgium]
  • Process Change: If previously invoices were sent by email/post, the process changes to either an automated dispatch to the AP or uploading to a portal. This might require changes in the ERP’s output management. For instance, instead of printing a PDF, SAP might now create an XML and push it to a web service. Companies often implement a central invoicing cockpit or dashboard to monitor e-invoice statuses (sent, delivered, acknowledged, errors).
  • Testing and Validation: Implementation requires robust testing – ensuring that various invoice scenarios (different VAT treatments, credit notes, intra-company invoices, etc.) are correctly represented in the XML. In Belgium’s case, one must check that scenarios like credit notes properly reference the original invoice ID (a compliance requirement) and that any unique business cases (e.g., self-billing, consignment stock invoices) can be handled in the e-invoicing solution. Companies have found having an EDI/E-invoicing specialist on the project team is critical to troubleshoot mapping and format issues. [Learnings…ct Belgium]
• External Service Providers: Many firms will leverage external e-invoicing platforms such as Tungsten, Pagero, OpenText, Basware, Sovos or others, which act as their Peppol access point. The challenge then is to onboard and configure the provider’s solution to the company’s needs. This involves:
  • Setting up connectivity from ERP to the provider (typically secure FTP or API).
  • Configuring the routing rules – e.g., which invoices go to Peppol vs other channels. (During transition, some customers may not be on Peppol yet, so the provider might send a PDF email for those as an interim measure if allowed by the business.)
  • Ensuring the provider is certified for Belgium’s requirements, including any specific code or field (Belgium mostly sticks to standard, but e.g. enterprise number usage needs to be correct).
  • Migrating any current EDI connections onto the provider’s system or mapping them to the new format.
  • Handling exceptions: The system should alert if an invoice fails to deliver (e.g., if the buyer is not registered on any Peppol directory). The company must have processes to resolve such cases, perhaps contacting the customer for an alternative method or inviting them to join the network.
• Inbound (Accounts Payable) Adjustments: For receiving supplier invoices, instead of scanning paper or manually keying PDFs, companies will start getting XML invoices. They need an efficient way to process these:
  • Workflow integration: E-invoices should ideally flow into the company’s AP workflow tool, matching with POs or being routed for approval just like before, but with less manual entry. If previously a scanning/OCR solution was used, this may be replaced or complemented by an e-invoice import module (for Belgium, formats like UBL can directly feed into many AP automation tools).
  • Multiple Channels: During the transition, AP departments might temporarily manage both electronic and paper invoices. Clear internal guidelines are required for handling both. Notably, for Belgium from 2026, many invoices that used to arrive by email PDF will likely stop – suppliers are supposed to send via Peppol. The AP team should monitor that expected e-invoices are indeed received. Belgium’s approach will reduce reliance on scanning: in fact, scanning and manual posting processes will be phased out for in-scope invoices by 2026. Preparing for this, companies can streamline or eliminate their scanning operations for Belgian invoices. [Belgium E-…& Posting]
  • Supplier communication: It may fall on companies (especially large ones) to communicate with smaller suppliers about sending e-invoices. Large buyers might assist suppliers in adopting the new format (some provide supplier portals where small vendors can input invoices that then convert to e-invoices). Ensuring all regular vendors know of the requirement and have a solution in place is a practical challenge for procurement/AP teams.
• Training and Change Management: Finance and tax teams will need training on the new tools:
  • Accounts receivable personnel must learn how to monitor e-invoice delivery statuses, handle any rejections or failures, and answer customer queries about e-invoices (for example, if a customer says they didn’t receive it, the AR team should know how to track it via the AP provider’s portal and perhaps resend or revert to an agreed fallback).
  • Accounts payable personnel will transition to checking an e-invoice queue instead of a paper inbox. Exception handling (price mismatches, etc.) remains, but they might be doing it within an e-invoice portal or ERP screen with the XML data.
  • Tax and compliance teams should update their VAT compliance checklists – e.g., verifying that for each VAT filing period, all invoices were indeed sent via the mandated channel, and archiving is in place. They should also monitor the official FAQ and updates from authorities (Belgium’s FPS Finance periodically updates guidance in response to business questions). [vatcalc.com]
  • IT teams need to maintain the new integrations and be on standby to adapt to any changes (for instance, if Belgium updates its requirements or if the business expands to new countries with other formats).
  • Overall, cross-functional collaboration is key. Many companies set up a dedicated e-invoicing project team (Finance, IT, Tax, Procurement) to oversee the implementation, then a steady-state governance to handle ongoing compliance.
• Data Quality & Master Data: One lesson learned from early adopters is the importance of accurate master data:
  • Customer/Vendor Records: Must include correct names, addresses, VAT IDs. The e-invoice will use these details, and errors can lead to rejection or mis-routing. For example, a wrong VAT number might mean the invoice can’t find the recipient in Peppol and fails delivery. Companies often undertook a master data clean-up before e-invoicing go-live, which in one case in Belgium led to blocking over 1,000 outdated customer records to avoid mistakes. [Learnings…ct Belgium]
  • Tax Configuration: The ERP’s tax codes should map cleanly to the e-invoice’s representation of VAT. Belgium’s VAT rules (e.g., exemptions, intra-community supply, reverse charge) all have specific ways to be represented in EN 16931 (using standard codes). Ensuring the ERP tax determination populates the correct codes and explanations on the e-invoice is a meticulous task.
  • Unique Invoice Requirements: Belgium doesn’t impose extra fields beyond EN 16931, but businesses still need to consider if they have any custom invoice elements (like specific reference fields for certain customers, or internal codes). If these are outside the standard, they may need to be sent in a structured way (possibly using the “Buyer reference” or “Project reference” fields in the standard) or dropped if not critical. Aligning on this with customers can avoid disputes.
• Stakeholder Coordination: The e-invoicing implementation touches multiple stakeholders:
  • The tax team must interpret legal requirements (like making sure a credit note references an invoice, how to handle self-billing or summaries) and work with IT to reflect these in the system.
  • The IT/EDI team handles technical development and integration.
  • The business units (e.g. order management, billing departments) need to adjust their procedures (like no longer printing invoices).
  • Often, involving someone with prior EDI (Electronic Data Interchange) experience significantly helps, since e-invoicing is essentially modern EDI. Their expertise with mapping and partner onboarding can smooth out technical barriers. [Learnings…ct Belgium]
  • External partners: coordination with the chosen e-invoicing service provider is crucial — including timelines for their deliverables, testing schedule, and support.
• Challenges for Finance Teams: From a finance perspective, some challenges and how to mitigate them include:
  • Initial Investment: There are costs for new software, possibly new hardware or cloud services, and training. However, the available tax incentives (20% investment deduction) help offset this, and long-term operational savings (less paper, manual work) are expected. [vatcalc.com]
  • Parallel processes: During the transition (2024–2025), finance teams might have to maintain both old and new invoicing processes. This can be burdensome. Clear internal cut-off plans help (e.g., decide a date in 2025 when you will only send e-invoices to customers who are ready, etc.).
  • Resistance or Readiness of Partners: Not all customers or suppliers may be ready by 2026, especially smaller ones. Finance teams may need to communicate the legal requirement and possibly offer support or alternatives. Fortunately, the Belgian government has resources and is promoting awareness, and since it’s a legal mandate, businesses are generally compelled to comply.
  • Error handling: When an e-invoice fails (due to technical reason or wrong data), the finance team must correct it quickly to avoid impacting cash flow or VAT records. This is a new kind of troubleshooting – e.g., resolving why an invoice was rejected by a recipient’s system (maybe a data format issue). Defining a clear process for such corrections (issue credit note if needed, re-issue invoice with corrections, etc., all electronically) is part of the change.
• Opportunities: On the positive side, integration can bring benefits:
  • Faster invoice delivery and payment: E-invoices reach customers faster than postal mail, which can lead to quicker payments and better cash management. Public entities in Belgium using e-invoices have seen reduced processing times.
  • Cost savings: Reduced printing, postage, and manual handling costs. Over time, these savings can be significant.
  • Automation and efficiency: With invoices in digital form, reconciliation and posting can be automated to a larger degree, freeing finance staff for higher-value tasks.
  • Real-time tax oversight: Companies can use the data to ensure compliance continuously. Some may even opt to reconcile VAT on a transaction basis, nearly eliminating surprises at filing time.