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FAQ on E-Invoicing implementation in Belgium

6 days ago
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12 min read

Update: May 6, 2026

Specific questions on e-invoicing

  • Question 22 modified
  • Question 27-32 added

See also

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Other articles

  • The Belgian e-invoicing FAQ has been updated to address several aspects, including formal recognition of Peppol invoice delivery delays (requiring investigation if over one working day) and clarification on reverse charge invoices that may lack specific wording but include “reverse charging of VAT.”
  • New guidance covers handling incorrectly addressed invoices: recipients must reject unintended incoming invoices electronically via Peppol using code “RE,” while senders of incorrectly addressed outgoing invoices (where VAT is chargeable) must register them, include them in VAT returns, and issue a credit note referencing the original Peppol ID.
  • The FAQ also clarifies that for self-billing, the supplier or service provider, as the invoice recipient, must register on Peppol, and a prior agreement and acceptance of each self-billing document remain prerequisites.

Source Thomson Reuters

Update: December 26, 2025

Belgian tax authorities provide clarifications on the upcoming mandatory B2B e-invoicing

  • Mandatory E-Invoicing Implementation: Belgium’s tax authorities confirmed that the mandatory B2B e-invoicing regime will commence on January 1, 2026, with no transitional delays. Businesses are urged to finalize their readiness for Peppol-based structured e-invoicing.
  • Key Compliance Guidelines: The updated FAQ clarifies that invoices issued on or after January 1, 2026, must be structured electronic invoices, and input VAT can only be claimed if compliant e-invoices are received. Written opt-out agreements are recommended for businesses wishing to use alternative formats to Peppol.
  • Phase-Out of Hermes and Public Entity Verification: The Hermes e-invoicing platform will be decommissioned on December 31, 2025, requiring businesses to transition to Peppol-compatible solutions. Additionally, companies can verify public entities subject to B2G e-invoicing through the Crossroads Bank for Enterprises (CBE) portal.

Source Fiscal Requirements

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

 

FAQs on e-invoicing requirements updated

  • Belgium’s Federal Public Service Policy and Support (FPS BOSA) has released updated FAQs confirming that the B2B e-invoicing mandate starts January 1, 2026, with applicability determined by the invoice date, not the transaction date.
  • The guidance clarifies rules for credit notes (following the original invoice’s format), the current stance on VAT deduction rights (prioritizing VAT neutrality over strict e-invoice possession for now), and the exploration of a transitional regime for businesses with genuine implementation challenges.
  • Additionally, the official Hermes e-invoicing platform will be discontinued as of December 31, 2025, requiring current users to switch to alternative service providers.

Source Deloitte

Here are the 5 key updates from Belgium’s latest e-invoicing FAQ:

  • Invoice issue date determines mandate applicability Structured electronic invoices are required for any invoice issued on or after 1 January 2026 — even if the underlying transaction occurred earlier. Credit notes must match the format of the original invoice.
  • Input VAT deduction at risk if non-compliant Businesses must receive structured electronic invoices to claim input VAT. Using unstructured formats (like PDFs) for mandated transactions may jeopardize VAT recovery unless exceptions apply.
  • Peppol opt-out requires written mutual agreement Deviating from Peppol is only allowed if both parties explicitly agree in writing and use formats compliant with EU standards (EN16931). Implicit agreements are discouraged.
  • Hermes platform decommissioned by 31 December 2025 Businesses using Hermes must migrate to alternative systems before year-end. Coordination with Peppol service providers is advised to ensure continuity.
  • B2G contracting authorities easier to identify Companies can now verify if a customer is a “Contracting Authority” subject to B2G e-invoicing via the Crossroads Bank for Enterprises (CBE), under the “Capacities” section.

Source PwC

  • E-invoicing streamlines the processes of sending, receiving, and managing invoices, offering a more efficient and environmentally friendly
  • alternative, with a comprehensive FAQ section addressing common queries related to principles, legal requirements, and technical aspects.
  • The FAQ is organized into themes, covering topics such as the basics of electronic invoicing, mandatory e-invoicing obligations for businesses (B2B) and governments (B2G), storage requirements for electronic invoices, and information on the Peppol network for document exchange.
  • Additional resources include guidance for software developers and tax experts, information on future e-reporting obligations, and links to external articles for detailed answers, alongside recommendations for consulting with organizations and accountants for further assistance.

Source efactuur.belgium.be

General questions about electronic invoicing

  1. What is an electronic invoice?
  2. What is a “regular” electronic invoice?
  3. What is a structured electronic invoice?
  4. What format do structured electronic invoices need to be in?
  5. How can I send structured electronic invoices to all my customers and receive them from all my suppliers?
  6. How can an alternative format comply with the European Norm?
  7. Are PDF invoices still legal?
  8. Are electronic invoices secured? Is e-invoicing safe?
  9. What are the advantages of e-invoicing?
  10. What are the misconceptions about e-invoicing?/a>
  11. How does electronic invoicing work? What is UBL? What is the Peppol network and the “Peppol-BIS” format?
  12. What is the European Standard (EN16931)?
  13. Does the mutual agreement for an alternative format or alternative shipping method have to be explicit, or does an implicit agreement suffice?
  14. Does the General Data Protection Regulation (GDPR) also apply to e-invoicing?

General questions about the B2B obligation (invoicing companies)

  1. Has Belgium received Europe’s authorisation to introduce the obligation?
  2. Is e-invoicing compulsory in Belgium? For which B2B transactions does the obligation not apply? Is e-invoicing also compulsory if I only work for private individuals? When will e-invoicing become compulsory? How do you know if a company is liable for VAT? Is e-invoicing also mandatory if I apply the Small Enterprises exemption scheme? Is e-invoicing also mandatory for farmers under the special agricultural scheme? Is e-invoicing also mandatory for persons liable to VAT not established in Belgium without a permanent establishment?
  3. How can I prepare my company for e-invoicing?
  4. What software do I need for e-invoicing?
  5. Are there any costs associated with using e-invoices? Are there any tax incentives for adopting e-invoicing?
  6. Can I also use e-invoicing outside Belgium, international?
  7. What should I do if my supplier is not ready on 1 January 2026?
  8. What should I do if my customer is not ready to receive invoices via Peppol on 1 January 2026?
  9. Can I use structured e-invoices if they are not compulsory?
  10. Is self-billing authorised?
  11. Can electronic and paper invoices coexist?
  12. Is it mandatory to send the invoice as a PDF attachment?
  13. The list of solutions is rather extensive. Can the government themselves offer a free solution for small businesses? Can you add the type of software to the list? Can you add the price to the list? Can the government reduce the list to a more limited number of choices for small businesses?
  14. When does e-invoicing become mandatory?
  15. Should I ask my customers for a Peppol ID?
  16. Is a structured electronic invoice sufficient on its own, without the issuance of a receipt from a registred cash register system?
  17. Should the PDF invoice attached by the sender or created by the recipient be kept?
  18. Can I be obliged to submit my invoices through a customer portal?
  19. Can I submit attachments through another channel (e.g. e-mail)?
  20. Why must attachments be sent through the same channel?
  21. Can I send attachments within the Universal Business Language (UBL)?
  22. What happens if I do send attachments separately?
  23. The software I am using does not yet allow for the sending or receipt of self-billing invoices (invoicing by the contracting partner) and does not yet process them automatically. Am I at risk of sanctions?

General questions about the B2G obligation (invoicing to governments)

  1. Is e-invoicing to governments mandatory? How do you send invoices to the government?
    1. How do you send invoices to the government? – e-invoice
    2. How to work with electronic invoicing? | BOSA
  2. How can I check if my customer qualifies as a government that requires e-invoicing?

General questions about the storage of electronic invoices

  1. How long do I have to keep my electronic invoices?
  2. If I receive both paper and electronic invoices, can I archive them in the same format?
  3. Can I archive an electronic invoice on paper?
  4. Can I archive a paper invoice electronically?
  5. Is archiving via ‘cloud computing’ allowed?
  6. How should I store my electronic invoices?
  7. How can I guarantee the readability, authenticity and integrity of electronic invoices, taking into account the rapid obsolescence of IT solutions?
  8. Is the choice of the method of archiving invoices subject to prior approval from the FPS Finance?
  9. Where should I keep my invoices?
  10. Can I use the services of an intermediary (service provider) for my archiving?
  11. What should I do if a third party (e.g. in the case of central archiving within a group) is unable to comply with the Belgian legal obligations regarding archiving?
  12. What are the consequences of an IT problem? How to arm yourself against it?
  13. What are my obligations in the event of a tax audit?
  14. What is the ‘authenticity of origin’ of the invoice? What is the ‘integrity of the content’ of the invoice? What is the ‘legibility’ of the invoice? When is an audit trail reliable?

General questions about Peppol

  1. What is Peppol?
  2. How does Peppol work?
  3. What is a Peppol service provider?
  4. What is a Peppol ID?
  5. How can I register my company on Peppol?
  6. As an entrepreneur, can I look up which customers or suppliers are connected to Peppol?
  7. Does the government consult the companies on the practical implementation? What is the Business Expert Group on E-invoicing?
  8. Does the government monitor the correct use of Peppol? Is there a Belgian Peppol authority (PA)?
  9. I am registered on Hermes. What should I do?

Specific questions about e-invoicing

  1. What happens if the customer only accepts the new format while the transition period is still underway (for example, when a new version of Peppol-BIS is released)?
  2. How can my company become a Peppol service provider?
  3. What about the specific requirements of public authorities (eg. third-party payment system)?
  4. Are duplicate invoices a problem for Peppol?
  5. Are credit notes also sent via Peppol?
  6. Are annexes to invoices also sent in XML format via Peppol?
  7. Can different Tax Category Codes appear on the same invoice?
  8. Can the Tax Category Code “0” be combined with other Codes (like “E” or “S”) on a same invoice?
  9. The list of exemption codes (VATEX) is not full. Which code should I use if an exemption is not included in the list?
  10. Can different “grounds for exemption” be mentioned for several lines of a same invoice with the Tax Category Code “E”?
  11. Can extended VAT clauses (e.g. reverse charge mechanism), which must be mentioned on the invoice in accordance with Belgian VAT legislation, also be included on a Peppol invoice?
  12. What happens when different orders have to be included on a single Peppol invoice?
  13. Is it possible to use different currencies on an invoice?
  14. In which field should the data for the register of legal entities (RPM), legal form and “in liquidation” be entered?
  15. How can I declare part of the costs mentioned on private invoices as business expenses? When can I exercise my right to deduct the VAT shown on my incoming invoices?
  16. Can I still send summary invoices?
  17. Can the date of the taxable event by supply of goods or services be included?
  18. Can I still send simplified invoices (art. 13 RD1)?
  19. Can I draw up an invoice in several languages?
  20. What is an extension?
  21. Where do I mention the buyer’s (authorised) tax representative?
  22. How does self-billing through Peppol work?
  23. Should a 2026 credit note relating to a 2025 invoice be issued as a structured electronic invoice (SEI)?
  24. As a customer, do I risk losing my right to deduction if I do not have a structured electronic invoice (SEI)?
  25. What about authorised representatives?
  26. What sanctions can be imposed for non-compliance ?
  27. The invoice does not include the mandatory detailed information required in the event of reverse charge (RD No. 1, Article 20, § 3). Should I reject the invoice or ask for it to be corrected?
  28. I have received an invoice that is not intended for me (no goods or services have been provided; for example, the sender has misidentified the recipient). What should I do?
  29. When sending the invoice, I have misidentified the recipient. What should I do if I notice that an outgoing invoice has been sent to the wrong recipient?
  30. Does the new e-invoicing requirement also apply to transactions referred to in Articles 12 and 19 of the VAT Code (disposals and first occupations)?
  31. Which Tax Category Code should be used for special VAT schemes (margin scheme, recovered products, etc.)?
  32. What is the minimum information that must be included for an invoice to comply with Belgian law?

General questions about e-reporting

  1. Does the information from the invoice also have to be reported to the government (so-called e-reporting, or ‘near real-time reporting’)?
  2. Why is Belgium introducing such an obligation?
  3. Does the measure also apply to intra-Community transactions (IC)?

See also Belgium (Briefing document)

Useful links

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

 

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