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

Last update: December 4, 2025

SUMMARY

Executive Summary:

Belgium is implementing mandatory electronic invoicing (e-invoicing) for Business-to-Business (B2B) transactions, starting January 1, 2026, followed by near real-time electronic reporting (e-reporting) by January 1, 2028. These initiatives are aligned with the EU’s VAT in the Digital Age (ViDA) initiative and aim to modernize VAT administration, reduce fraud, and improve compliance. This document outlines the key aspects of these changes, including scope, timelines, technical requirements, and potential penalties.

Key Dates and Timelines:

January 1, 2026: Mandatory B2B e-invoicing goes live for domestic transactions between Belgian VAT-registered businesses. A “grace period” exists for Q1 2026.
January-March 2026: A 3-month tolerance period or “grace period” is in effect. No fines will be imposed for e-invoicing infractions if the company can demonstrate it tried to implement e-invoicing on time.
After March 31, 2026: Full enforcement of e-invoicing mandates, including penalties, applies.
January 1, 2028: Near real-time e-reporting to the tax authorities commences, replacing the annual VAT client listing.
July 1, 2030: Belgium will implement intra-EU transaction reporting, aligning with the EU’s ViDA initiative.

Scope of E-Invoicing:

In Scope (from Jan 1, 2026): Domestic B2B transactions where both supplier and customer are VAT-registered and established in Belgium, and the supply of goods or services is located in Belgium. This includes B2B sales and credit notes.
- As the document specifies, “any invoice between two Belgian VAT-registered businesses must be electronic (structured) if the transaction is subject to Belgian VAT”
Out of Scope:B2C transactions (invoices to private individuals)
- VAT-exempt entities making only exempt supplies (e.g., financial, medical, educational institutions)
- Certain small or special-regime taxpayers (e.g., “flat-rate” VAT payers and bankrupt businesses) until those regimes are phased out by 2028.
- Cross-border B2B transactions (until the EU-wide mandate in 2030).
- Imports and Exports (Extra-EU)
- Foreign companies not established in Belgium but merely holding a Belgian VAT registration are excluded from the 2026 e-invoicing mandate. However, such foreign businesses must be able to receive Belgian e-invoices.
B2G: “Public sector (B2G) invoicing is governed by a separate framework”

Format and Technical Requirements:

Structured Electronic Invoices: E-invoices must conform to the European standard for e-invoicing (EN 16931), specifically the Peppol BIS 3.0 format (UBL 2.1), which is a structured XML format.
- The document states that “Unstructured invoices (PDF, Word, paper) will no longer suffice for compliance after Dec 31, 2025.”
Peppol Network: Transmission will primarily occur via the Peppol 4-corner model. Taxpayers must have the technical capability to use Peppol.
- “The July 2025 Royal Decree confirmed that all taxpayers must have the technical capability to use Peppol , even if they also agree on alternative channels.”
Invoice Content: E-invoices must contain all legally required invoice information (supplier and customer details, VAT numbers, invoice date and number, description of goods/services, quantity, price, VAT rates, etc.) in a machine-readable form.
E-Reporting (from 2028): Belgium plans to use a Peppol 5-corner model. As an invoice is exchanged via Peppol between supplier and buyer, a copy of the invoice data will be routed to the government in near real-time.
The goal is that invoice data is transmitted to the authorities “almost immediately after issuance“.

Data Archiving:

Businesses must store electronic invoices for at least 10 years, counted from the start of the year following the invoice date.
Invoices must remain readable, and their integrity and authenticity guaranteed. Electronic archiving is encouraged. Electronic invoices do not need to be printed.
During a tax audit, the tax authority can request a download of the data or direct access to the system.

Compliance and Penalties:

Lack of valid E-Invoice means No VAT Deduction: A PDF or paper invoice (when a structured e-invoice was required) is considered non-compliant.
Proportional Fines: A supplier who does not issue a proper e-invoice can face a fine ranging from 60% up to 100% of the VAT due on the transaction.
Fixed Fines for technical non-compliance: €1,500 for the first offence, €3,000 for a second offence, and €5,000 for a third offence within a short period (three months).
“The grace period in Q1 2026 means these fines would not be imposed for infractions in that period if the company shows it is working in good faith to comply”
After e-reporting begins in 2028, the tax authority will have increased visibility to enforce compliance, likely leading to increased audits and potentially stringent VAT penalties.

Relation to Pre-Filled VAT Returns:

Belgium is not currently offering pre-completed VAT returns to taxpayers using the e-invoice data. Taxable persons must still file their periodic VAT returns as usual.
The separate annual client listing will be eliminated from 2028 onward.

Alignment with EU’s VAT in the Digital Age (ViDA):

Belgium’s e-invoicing and e-reporting initiative is aligned with the EU’s ViDA reforms, which mandate e-invoicing for cross-border intra-EU transactions and digital reporting of those transactions by 2030.
Belgium’s approach positions the country ahead of schedule, and the Belgian model (Peppol network, 5-corner reporting) is serving as a test case.
Belgium will implement intra-Community transaction reporting by mid-2030 at the latest.

Recommendations:

Businesses should begin preparing their accounting systems to handle Peppol e-invoices.
Ensure compliant archiving procedures are in place.
Understand the potential penalties for non-compliance.
Stay informed about updates and clarifications from the Belgian tax authorities.
Prepare to be able to receive electronic invoices, even if your business isn’t required to send them.

INDEPTH ANALYSIS

Implementation Timeline: Belgium will roll out mandatory electronic invoicing (e-invoicing) for business-to-business (B2B) transactions from 1 January 2026, followed by a near–real-time electronic reporting (e-reporting) requirement in January 2028. Key dates and phases include: [einvoice.belgium.be], [einvoice.belgium.be]

Jan 1, 2026 – B2B E-Invoicing Go-Live: As of this date, almost all invoices between Belgian VAT-registered businesses (domestic B2B transactions) must be issued in a structured electronic format. The legal mandate was published in early 2024, confirming the 2026 start and aligning Belgium with the EU’s drive towards digital VAT compliance. Notably, the government has not delayed the 2026 start, but it has provided a “grace period” for early 2026 (see below). [einvoice.belgium.be] [deloitte.com]
Grace Period (Q1 2026): Although the mandate takes effect in January 2026, authorities announced a 3-month tolerance period for businesses making genuine efforts to comply. Between January and March 2026, no fines will be imposed for e-invoicing infractions if the company can demonstrate it tried to implement e-invoicing on time (for example, if technical systems were in progress). During this window, businesses must still meet invoicing obligations (e.g. sending PDF invoices via email if they aren’t yet fully e-invoice ready). The grace period is not a postponement of the law – January 1, 2026 remains the official start – but rather a soft-landing where compliant companies won’t be penalized immediately for technical ramp-up issues. After March 31, 2026, full enforcement (including penalties) applies. [deloitte.com], [deloitte.com] [deloitte.com]
Jan 1, 2028 – Near Real-Time E-Reporting: Beginning 2028, Belgium will introduce “continuous” transaction reporting to the tax authorities in near real-time. Under this system, whenever a B2B invoice is issued, its data will also be transmitted to the Belgian tax administration through the same network (the Peppol network) almost immediately. This e-reporting requirement, slated in a 2025–2029 federal coalition agreement, is designed to replace the annual VAT client listing (the yearly summary of B2B sales) with transaction-level reporting. The 2028 e-reporting mandate complements the 2026 e-invoicing: it does not change which transactions must be e-invoiced, but adds an obligation to relay invoice data to the government in real time. (Technical details are under development by the tax authorities in 2025–2027.) [vatcalc.com], [news.pwc.be] [taxually.com] [einvoice.belgium.be], [news.pwc.be]
Future EU Alignment (2030 and beyond): Belgium’s roadmap is aligned with the EU’s VAT in the Digital Age (ViDA) initiative. The EU has approved Union-wide digital reporting rules that will make structured e-invoicing mandatory for all intra-EU B2B transactions by 1 July 2030. Belgium has signaled it will implement intra-EU transaction reporting in national law by that deadline. In practice, this means that cross-border (EU) invoices will be brought into a real-time reporting system by 2030 in line with European requirements. Additionally, the EU is expected to permit or require e-invoicing for domestic transactions across all Member States by 2030–2035. By moving early (2026/2028), Belgium is ahead of these EU mandates and will already satisfy the ViDA obligations when they kick in. (Belgium is even participating in a Peppol pilot project with other tax administrations to shape the EU-wide reporting standards.) There are no pre-filled VAT returns provided to taxpayers as part of this rollout – the focus is on real-time data capture and improved compliance, rather than having the tax authority prepare taxpayers’ periodic returns for them (the periodic VAT return filings remain the businesses’ responsibility, though in the future the accumulated data could enable pre-filled drafts). [einvoice.belgium.be] [deloitte.com], [vertexinc.com] [news.pwc.be]

Scope of Transactions Covered: The e-invoicing mandate covers domestic B2B transactions in Belgium, with specific scope limitations and future extensions as follows:

Domestic B2B: In scope from 2026. The obligation applies to supplies of goods or services located in Belgium between VAT-taxable persons established in Belgium. In practice, any invoice between two Belgian VAT-registered businesses must be electronic (structured) if the transaction is subject to Belgian VAT (including domestic reverse-charge transactions). This includes B2B sales and credit notes where both supplier and customer are Belgian VAT payers. (Example: A Belgian company selling to another Belgian company must issue an e-invoice for that sale.) [rsm.global], [grantthornton.be] [grantthornton.be] [einvoice.belgium.be]
- Exclusions (Domestic): Business transactions that fall outside normal VAT invoicing requirements or involve special sectors are excluded. Notably, B2C transactions are entirely out of scope – invoices to private individuals can continue in paper/PDF form. Also, VAT-exempt entities that make only exempt supplies under Article 44 of the VAT Code (e.g. many financial, medical, or educational institutions) are not required to use e-invoicing for their sales. Similarly, certain small or special-regime taxpayers are exempt: for example, Belgium’s “flat-rate” (forfait) VAT payers and bankrupt businesses (with an active VAT number) are carved out until those regimes are phased out by 2028. These are relatively limited exceptions. Public sector (B2G) invoicing is governed by a separate framework – Belgium already made e-invoicing to government mandatory for public contracts (gradually since 2017, and fully for contracts ≥ €3,000 as of March 2024), so B2G is not part of the 2026 B2B mandate (it was addressed earlier by other laws). [einvoice.belgium.be] [rsm.global], [grantthornton.be] [grantthornton.be]
Cross-Border Transactions (Intra-EU and Export): Not in scope for 2026 e-invoicing. The mandatory e-invoice requirement does not extend to cross-border B2B sales or purchases. If either the seller or buyer is not established in Belgium, the transaction is outside the national mandate. For example, an invoice from a Belgian company to a VAT-registered client in France, or a purchase by a Belgian company from an EU supplier, is not required to be issued in the Belgian e-invoice system. Such transactions remain subject to existing EU VAT rules (e.g. EC Sales List reporting, etc.) until the EU-wide mandate kicks in by 2030. Intra-Community (EU) B2B flows will eventually be covered by the EU’s own digital reporting requirement (as per ViDA) starting 2030. Belgium has stated it will implement a similar real-time reporting for intra-EU transactions by 1 July 2030 in line with that European framework. Until then, Belgium’s 2028 e-reporting is focused on domestic transactions (between Belgian firms). [vatcalc.com], [grantthornton.be] [einvoice.belgium.be], [news.pwc.be] [einvoice.belgium.be]
- Imports and Exports (Extra-EU): Sales from Belgium to customers outside the EU, or purchases from non-EU suppliers (imports), are also not subject to the domestic e-invoicing mandate. Such transactions typically have no Belgian VAT on the invoice (exports are zero-rated, imports are taxed via customs/VAT declaration), so they fall outside “transactions located in Belgium” for invoicing purposes. There is currently no special real-time reporting for these in Belgium beyond existing customs and VAT return procedures. (In the future, EU reforms may integrate more reporting for these flows, but Belgium’s announced plans do not specifically target extra-EU trades.) [grantthornton.be]
Non-Belgian Businesses: Only Belgian-established taxpayers are obligated. Crucially, foreign companies that are not established in Belgium (no Belgian fixed establishment) but merely hold a Belgian VAT registration are excluded from the 2026 e-invoicing mandate. Belgian authorities explicitly confirmed in 2024 that these “non-established VAT registrants” do not have to issue Belgian e-invoices for their sales in Belgium. For example, if a Dutch company is VAT-registered in Belgium to sell goods there but has no establishment, it is not required to adopt the Belgian e-invoicing system for its Belgian transactions (this aligns with EU policy under ViDA). However, such foreign businesses must be able to receive Belgian e-invoices from their Belgian customers or suppliers if those Belgian partners issue them. In practice, a non-resident seller or buyer can still use electronic invoices voluntarily, but they are not legally compelled by the Belgian rule in 2026. Note: This exclusion for non-established entities may be temporary; by 2028 when e-reporting begins, the government may include transactions involving foreign VAT-registrants so that all B2B sales get reported. It’s anticipated that even non-established companies will need to comply with the e-reporting obligation (meaning they’ll effectively need to use e-invoices to generate the required data) from 2028 onward, although Belgian law will be updated to clarify this. [deloitte.com], [vatcalc.com] [deloitte.com] [deloitte.com], [globalindi…gement.com]

Format and Data Requirements: The Belgian mandate is for “structured” electronic invoices that conform to a standard data format, ensuring automatic processing. Key points about format and content:

Standard Format (EN 16931): E-invoices must meet the European standard for e-invoicing (EN 16931). In practice, Belgium has adopted the Peppol BIS 3.0 format – a structured XML format (UBL 2.1) widely used in the EU. This means invoices will be issued as XML data files following a standardized schema, rather than as PDF or paper. Unstructured invoices (PDF, Word, paper) will no longer suffice for compliance after Dec 31, 2025. (Businesses can still send a PDF copy to trading partners for convenience, but the PDF has no legal value unless accompanied by the structured data.) The e-invoice file must contain all legally required invoice information (per the VAT Code and Royal Decree No.1, Article 5) in a machine-readable form. This includes: supplier and customer details and VAT numbers, invoice date and number, description of goods/services supplied, quantity, unit price, taxable amount per VAT rate, applicable VAT rates, the VAT amount for each rate, any exemptions or reverse-charge notation if applicable, etc. These content requirements themselves are not new – the same info was required on paper invoices – but now they must be present in the structured electronic format. (Notably, a new rule on VAT rounding will apply: from 2026, any rounding of VAT can only be done on the invoice total per VAT rate, not line by line, to ensure the data sums correctly in the automated system.) [edicomgroup.com], [vatcalc.com] [vatcalc.com] [grantthornton.be], [grantthornton.be] [edicomgroup.com]
Transmission via Peppol Network: Belgium’s system is based on the Peppol 4-corner model for e-invoice exchange. Peppol is an EU-endorsed network through which businesses and software providers exchange standard e-invoice files. Each company can use a certified Peppol Access Point (often built into invoicing or ERP software, or provided by a service provider) to send and receive invoices. Under the 2026 B2B mandate, Peppol will be the default channel: the typical workflow is that the supplier’s system sends the e-invoice through a Peppol access point, and the buyer receives it through their access point, all in a secure interoperable way. The July 2025 Royal Decree confirmed that all taxpayers must have the technical capability to use Peppol, even if they also agree on alternative channels. In fact, other e-invoicing delivery methods (e.g. direct EDI connections between trading partners) are allowed only if they comply with the same European standards (semantics and syntax per EN 16931). So two companies could continue using an existing EDI system or a different platform, provided the invoices they exchange contain all required data in the standard format. However, since every company must be Peppol-capable, even if a different method is used by mutual agreement, each business must still be able to switch to Peppol if needed. This ensures universal interoperability. (Peppol is also already used for Belgian B2G invoices – via the Mercurius platform – so many businesses are familiar with it.) [vatcalc.com], [vatcalc.com] [edicomgroup.com] [edicomgroup.com], [edicomgroup.com]
No Direct Tax Submission in Phase 1: In the initial e-invoicing phase (2026–2027), issuing an e-invoice to your customer does not automatically mean reporting it to the government. The law does not require sending invoice data to the tax authority in 2026. The e-invoice travels from supplier to buyer through the network, and the tax authority is not routinely in the loop at this stage. (Companies will continue filing monthly/quarterly VAT returns and the annual client listing as before in 2026–27.) The real-time tax connection begins in 2028 with e-reporting. [vatcalc.com]
E-Reporting Data and Method (from 2028): When e-reporting goes live, the tax administration will effectively join the e-invoicing exchange network as a participant. Belgium plans to use a Peppol 5-corner model for this. In practical terms, this means that as an invoice is exchanged via Peppol between supplier and buyer, a copy of the invoice data will be routed to the government (the “fifth corner”). The Belgian tax authority will become an accredited Peppol receiver to get the data in near real-time. Businesses will likely fulfill the e-reporting requirement automatically through their access point/service provider or software, which will forward the required data to the tax authority’s system. The goal is that invoice data is transmitted to the authorities almost immediately after issuance – effectively at the same time it is delivered to the customer. Thus, the due date for reporting each invoice will be essentially upon issuance (or within a very short grace window to allow technical processing). This “continuous reporting” will eliminate the need for certain periodic reports (notably the annual sales listing). By having invoice-by-invoice details, the tax authority can cross-check VAT declarations more easily and even detect errors or fraud sooner. (Exact technical specifications for the 2028 reporting (such as whether data must be transmitted within X hours or days if not instant) are expected in future guidance, but the intent is clearly near real-time reporting rather than a monthly batch.) [vatcalc.com], [news.pwc.be] [news.pwc.be], [news.pwc.be] [taxually.com] [news.pwc.be]
Archiving Requirements: Businesses must store electronic invoices for at least 10 years (the standard record retention period for VAT in Belgium). This retention period is counted from the start of the year following the invoice date. For example, an invoice issued in June 2026 must be kept until at least January 1, 2037. The law has long required the same retention length for paper invoices (recently extended from 7 to 10 years in Belgium), and this applies equally to e-invoices. Originality and access: During the retention period, invoices must remain readable and their integrity and authenticity must be guaranteed. Companies are free to choose their archiving method (electronic archiving is encouraged) so long as the stored e-invoices cannot be altered and can be presented to the tax inspectors on request. It’s permissible to convert formats (for example, migrating data to new storage systems) as technology evolves, as long as the content stays intact and verifiable. Electronic invoices do not need to be printed – printing to paper is allowed but would destroy many benefits and is not recommended. In practice, companies will keep invoices in secure digital archives or cloud systems, often with backup copies. Belgian law does not require prior approval of the archiving solution, and invoices may be stored outside Belgium provided officials can access them online immediately when needed. During a tax audit, if records are kept electronically, the tax authority can request a download of the data or direct access to the system, and the business must be able to supply the e-invoices in a legible format promptly. Failure to meet archiving obligations (e.g., inability to produce an invoice, or altered records) can result in denied VAT deductions and fines. [einvoice.belgium.be], [accountable.eu] [accountable.eu] [einvoice.belgium.be] [einvoice.belgium.be], [einvoice.belgium.be]

Persons/Businesses in Scope: The mandate targets VAT-registered businesses established in Belgium. In summary:

Included: All Belgian-established taxable persons (companies, self-employed, partnerships, etc.) that engage in B2B supplies and are required to issue VAT invoices. This covers the vast majority of businesses registered for VAT in Belgium. Such businesses must both issue e-invoices for their sales to other businesses and be able to receive e-invoices for their purchases. (Even small businesses not in the VAT monthly/quarterly regime – e.g. those under the small entrepreneur exemption threshold – presumably fall out of scope since they don’t charge VAT and often don’t issue VAT invoices at all. The law mainly talks about those “liable to VAT”.) [rsm.global]
Excluded: The notable exclusions are: foreign suppliers without a Belgian establishment (as discussed above); businesses making only VAT-exempt supplies under Article 44 (they do not charge VAT and traditionally were not obliged to invoice those sales); and a few special cases like flat-rate farmers or bankrupt entities during insolvency proceedings. These groups do not have to adopt e-invoicing for now. Also, private individuals and entities not engaged in economic activities (non-VAT persons) are unaffected – the rules only concern VAT-taxable transactions. [deloitte.com] [rsm.global], [grantthornton.be] [grantthornton.be]
- Customers’ obligation to accept e-invoices: Any Belgian VAT-registered business in scope of the mandate is not only obliged to send e-invoices when it is the supplier, but also is effectively obliged to receive e-invoices when it is the customer. Starting in 2026, if a Belgian business issues an invoice to another Belgian business, that invoice must be electronic; the customer cannot insist on paper. Thus, all in-scope companies must be ready to receive/process e-invoices (for example, via a Peppol access point or compatible software). The 2024 law even initially required non-established VAT registrants to be able to receive e-invoices for their Belgian purchases, though as noted, those non-established are now fully excluded from the mandate. For Belgian-to-Belgian trade, the buyer is required to provide its VAT number to the supplier (as they do today) to indicate it’s a B2B transaction; this will signal that an e-invoice is required. If a customer were somehow unable or unwilling to receive a structured invoice, they would not have a “legally compliant invoice” for VAT purposes. In other words, paper or PDF won’t count for the deduction if an e-invoice should have been used. This encourages all businesses to get onboard with the necessary software by 2026. [vatcalc.com] [deloitte.com] [grantthornton.be]

Compliance and Penalties: Belgian authorities have put in place provisions to enforce the mandate and penalize non-compliance, though with some leniency initially:

No Invoicing, No VAT Deduction: A fundamental sanction in VAT law, which carries into the e-invoicing era, is that if a supplier fails to issue a valid invoice, the tax authority can refuse the VAT deduction for the customer. From 2026, a PDF or paper invoice (when a structured e-invoice was required) is considered non-compliant, meaning the customer might lose the right to deduct that VAT. Similarly, if a supplier doesn’t issue any invoice or issues one lacking mandatory info, it violates invoicing rules. Belgian VAT law provides for “proportional” fines in such cases – these are steep penalties calculated as a percentage of the VAT amount. According to the official mandate, a supplier who does not issue a proper e-invoice can face a fine ranging from 60% up to 100% of the VAT due on the transaction. In other words, the entire VAT amount (or a large portion of it) may be levied as a penalty. On the customer side, if they try to deduct VAT without a valid e-invoice, they risk a fine (generally 10% of the VAT improperly deducted). These are existing penalties under VAT law, now applicable to the e-invoice context – they underscore that failing to comply can have severe financial consequences (denied refunds/credits and punitive fines). [grantthornton.be]
Specific E-Invoicing Fines: In addition, the July 2025 Royal Decree introduced fixed fines for technical non-compliance with the e-invoicing requirements. If a business doesn’t adhere to the format/technology obligations (for example, they simply continue to send paper or their systems can’t receive Peppol invoices), the following administrative fines apply: €1,500 for the first offence, €3,000 for a second offence, and €5,000 for a third offence within a short period (three months). These fines target the failure to implement the e-invoice system itself (distinct from any VAT amount issues). They are often called “graduated” fines or a new penalty regime for e-invoicing, meant to encourage swift compliance. Each invoice or incident of non-compliance could trigger a fine, up to those limits. After the third offence, it’s expected that repeated violations will continue to incur €5,000 fines for each instance. Notably, the grace period in Q1 2026 means these fines would not be imposed for infractions in that period if the company shows it is working in good faith to comply. But once the grace period is over, a company still sending PDFs without justification could rather quickly accumulate penalties (e.g. €1,500 on the first missed e-invoice, €3,000 on the next, etc.). [edicomgroup.com] [edicomgroup.com], [vertexinc.com] [deloitte.com], [deloitte.com]
Enforcement and Audit: With e-reporting from 2028, the tax authority will have much more visibility to enforce compliance. Because invoice data will be reported in real-time, authorities can detect if a company is not submitting data (hinting they aren’t using e-invoices) or if data fields are consistently erroneous. The Belgian tax administration is known to impose stringent VAT penalties, and the digital system will enable more automated checks. We can expect increased auditing of VAT based on the e-invoice data. The combined effect of these measures is to tighten VAT control and shrink the “VAT gap” (Belgium estimates an annual €4+ billion shortfall from VAT non-compliance). Businesses should therefore view e-invoicing not just as an IT change but as a tax compliance imperative – errors or delays can quickly result in financial sanctions. [news.pwc.be] [news.pwc.be], [news.pwc.be]

Relation to Pre-Filled VAT Returns: As of the latest information, Belgium is not (yet) offering pre-completed VAT returns to taxpayers using the e-invoice data. The current reforms aim to collect invoice details rapidly and accurately, but taxable persons must still file their periodic VAT returns as usual (monthly or quarterly summarizing sales, purchases, etc.). The benefit of e-reporting is indirect: with all transactional data in hand, the tax authority can potentially pre-check or eventually pre-fill parts of declarations, but no official pre-population system has been announced for regular VAT returns. The immediate confirmed change is the elimination of the separate annual client listing from 2028 onward (since that information – the yearly total of B2B sales per customer – will be naturally available from the realtime reports). Some EU countries (like Italy) have begun providing draft VAT returns based on e-invoice data; Belgium’s 2028 plan could pave the way for similar conveniences in the future, but at present Belgian businesses will continue to prepare and submit their own VAT returns, with the assurance that the underlying invoice data they reported can be cross-verified. There is no indication of near-term “pre-filled” VAT returns by the Belgian FPS Finance under this e-invoicing program. [einvoice.belgium.be], [news.pwc.be]

Alignment with EU’s VAT in the Digital Age (ViDA): The Belgian e-invoicing and e-reporting initiative is closely aligned with pending EU-wide changes:

In March 2025, EU finance ministers (ECOFIN) approved the ViDA reforms, which, among other things, mandate e-invoicing for cross-border intra-EU transactions and digital reporting of those transactions by 2030. Belgium’s approach – mandatory domestic e-invoicing in 2026, then expanding to real-time reporting – positions the country ahead of schedule. By 2030, when all Member States must implement intra-EU e-invoicing and reporting, Belgium will already have an established system. In fact, the Belgian model (Peppol network, 5-corner reporting) is serving as a test case that aligns with ViDA’s interoperability goals. Belgium has been actively involved in European pilots (such as the Peppol-based ViDA pilot) to ensure its system will integrate smoothly with EU requirements. [einvoice.belgium.be] [edicomgroup.com], [news.pwc.be] [news.pwc.be]
Domestic E-invoicing and EU Law: Until ViDA, EU law required buyer consent for e-invoicing. Belgium obtained (or is in process of obtaining) a derogation from the EU VAT Directive to enforce mandatory e-invoicing nationally. This is similar to Italy’s path. The ViDA amendments will remove the need for such derogations by explicitly allowing Member States to mandate e-invoicing. Belgium’s timeline for domestic B2B (2026) precedes the EU’s likely deadline (the European Commission’s proposal envisages all Member States implementing digital reporting for domestic transactions by 2028–2032, with a long-stop date in 2035). By acting early, Belgium is both compliant with current EU law via derogation and well-positioned for the future state of harmonized digital VAT reporting. [vatcalc.com] [vertexinc.com]
Intra-EU reporting (ViDA): As noted, Belgium will implement intra-Community transaction reporting by mid-2030 at the latest. This will involve sending data on Belgian companies’ sales to EU customers (and possibly acquisitions from EU suppliers) to a central system that EU tax authorities share. ViDA essentially means Belgian companies will have to issue e-invoices for cross-border EU B2B sales by 2030, and those invoices’ data will be automatically reported to tax authorities across borders. Belgium’s e-invoicing infrastructure will make this a smooth extension, likely just expanding the scope of transactions that get fed into the 5-corner model. [einvoice.belgium.be]

In summary, Belgium’s e-invoicing mandate (2026) and e-reporting system (2028) mark a major digital transformation of VAT administration, bringing many advantages: faster data exchange, reduced fraud, and possibly simpler compliance in the long run. The mandate covers domestic B2B transactions by Belgian-established businesses, requiring them to use a standardized electronic format (Peppol/EN16931) for invoices. Transactions outside this scope (B2C, cross-border) are not mandated for e-invoicing at this stage. Starting 2028, invoice data for in-scope transactions must be transmitted to the tax authorities in near real-time, replacing the old annual sales listing and paving the way for modern VAT oversight. Businesses should prepare their accounting systems to handle Peppol e-invoices, ensure compliant archiving (10 years), and be aware of the penalties (graduated fines and VAT consequences) for failing to comply. While no pre-filled VAT returns are provided yet, the richer data environment will support better compliance and could lead to such innovations eventually. All these changes tie into the broader EU strategy (ViDA) to digitize VAT reporting across Europe by the end of the decade. [einvoice.belgium.be], [news.pwc.be]

Sources:

Belgian Federal Public Service (FPS Finance) – E-invoicing in Belgium – Official Portal (2024-2025): Explains the 2026 mandate scope and exclusions, confirms no data reporting in phase 1 and plans for 2028 near real-time reporting, and details archiving obligations (10-year retention, authenticity requirements). [einvoice.belgium.be], [einvoice.belgium.be] [einvoice.belgium.be], [einvoice.belgium.be] [einvoice.belgium.be], [einvoice.belgium.be]
Law and Official Gazette: Law of 20 December 2022 (published Feb 2024) enabling mandatory B2B e-invoicing from 2026 and Royal Decree of 9 July 2025 detailing technical standards and penalties. (See Deloitte Tax Alert summarizing the Royal Decree and scope changes.) [edicomgroup.com], [edicomgroup.com] [deloitte.com]
Deloitte Belgium – Indirect Tax Alerts (2024–2025): “Non-established entities excluded from the Belgian B2B e-invoicing mandate” and “Grace period but no postponement of e-invoicing mandate”. [deloitte.com] [deloitte.com], [deloitte.com]
Belgian Government Coalition Agreement (31 Jan 2025): Announced the 2028 e-reporting initiative (the “Arizona deal”), replacing client listings and extending fiscal cash registers. (Referenced in PwC Newsflash and Taxually report.) [news.pwc.be] [taxually.com]
PwC Belgium (Apr 2025): “Near real-time reporting by 2028” – overview of Peppol 5-corner model and ViDA alignment. [news.pwc.be], [news.pwc.be]
EDICOM / TJC / RSM (2025): Overviews of the Belgian mandate confirming Peppol BIS format, scope (B2B domestic, exclusions), and enforcement timeline. [edicomgroup.com], [rsm.global]
Vertex Inc. (Nov 2025): “Belgium 2026 E-Invoicing Explained” – quick facts on scope, archiving, and penalties. [vertexinc.com], [vertexinc.com]
Grant Thornton Belgium (Jul 2025): In-depth guide to formal VAT requirements under e-invoicing, including the 3-rule scope test and consequences for non-compliance (VAT deduction refusal, fines). [grantthornton.be], [grantthornton.be]
Taxually (Oct 2025): Highlights that e-reporting will transmit invoice data “almost immediately after issuance”, emphasizing the near real-time nature. [taxually.com]
EU Council – ViDA Agreement (Mar 2025): Political agreement by EU Member States to mandate e-invoicing for intra-EU transactions from 2030, which Belgium will transpose by the deadline. (See EU Council press release on the VAT in the Digital Age package.) [einvoice.belgium.be]

Interesting links

See also
- Briefing / Comprehensive Guides (incl. podcasts)

Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE

Transaction Type	Established Entities	Non-Established Entities	Mandate Status	Notes
B2G (Business to Government)	✅ Mandatory structured e-invoicing	✅ Mandatory structured e-invoicing	Active	Must use Peppol BIS via Mercurius platform
B2B (Business to Business)	✅ Mandatory from Jan 1, 2026	❌ Not mandatory unless fixed establishment	Confirmed	Applies to Belgian VAT-registered entities; exceptions for exempt and non-established entities
B2C (Business to Consumer)	❌ Not mandatory	❌ Not mandatory	Voluntary	No legal requirement for e-invoicing
E-Reporting (Domestic)	❌ Not yet mandatory	❌ Not yet mandatory	Planned for 2028	Near real-time reporting to replace annual customer listing
E-Reporting (Intra-EU)	❌ Not yet mandatory	❌ Not yet mandatory	Planned for July 1, 2030	In line with EU ViDA package for cross-border transactions

Latest Posts in "Belgium"

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

Latest Posts in "Belgium"

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