Tolerance Period of 3 months for E-Invoicing Implementation in Belgium

Belgium: tolerance in Q1 2026 for mandatory e-invoicing, go live remains 1 January 2026

Mandatory E-Invoicing Start Date: Belgium will implement mandatory structured electronic invoicing for B2B transactions starting January 1, 2026, using the Peppol BIS standard for automated processing. This requirement applies to VAT-liable businesses, emphasizing the transition to digital invoicing.
Q1 2026 Tolerance Period: The Belgian tax authorities announced a tolerance period during the first quarter of 2026, during which penalties for late issuance or receipt of structured e-invoices will not be enforced. Businesses must demonstrate that they made timely and reasonable preparations to comply with the new obligation.
Clarification on Tolerance: The tolerance period is not a postponement of the e-invoicing obligation, which remains effective from January 1, 2026. It is designed to assist businesses facing practical challenges despite having prepared adequately, with evaluations conducted on a case-by-case basis.

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Introduction of Mandatory E-Invoicing: Starting January 1, 2026, Belgium will implement mandatory e-invoicing for VAT-registered companies, marking a significant step towards digitalization. Over half a million companies are preparing for this transition, with increasing adoption rates as the deadline approaches.
Three-Month Tolerance Period: The FPS Finance will allow a grace period during the first three months of 2026, refraining from imposing sanctions for specific infringements related to the new e-invoicing obligation. Companies must demonstrate they have made reasonable preparations to comply, acknowledging that some may face practical challenges in fully implementing the requirements.
Conditions for Tolerance and Compliance Urgency: While the tolerance applies to companies lacking the necessary technical means to issue structured electronic invoices, the initiative is not a general postponement. Companies that fail to prepare adequately are encouraged to comply promptly, as sanctions will be assessed on a case-by-case basis to ensure fairness to those who have made efforts to meet the deadline.

Mandatory E-Invoicing and Grace Period: Belgium will enforce mandatory structured e-invoicing for domestic B2B transactions starting January 1, 2026. A grace period will be in place during Q1 2026 for businesses that demonstrate good-faith efforts to comply but encounter implementation challenges, allowing them to avoid penalties for specific breaches related to the new requirement.
Grace-Period Coverage and Requirements: The grace period applies only to issues directly linked to the new e-invoicing mandate, such as temporary inability to send or receive structured invoices or system limitations. Businesses must continue invoicing using alternative methods while working to implement structured invoicing, and they should prepare evidence of their readiness efforts, such as contracts and test transmissions.
Penalties and Compliance: After the grace period ends in April 2026, penalties for failing to send or receive structured e-invoices will be enforced, escalating for repeated violations. E-invoicing compliance relies on reciprocity among counterparties, and businesses must ensure all parties are prepared to facilitate a smooth transition to the new system, documenting any exceptions during the grace period.

Source RTC

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E-invoicing