Mandatory B2B Peppol E-Invoicing Live; 2028 E-Reporting Next

Summary

Since 1 January 2026, all Belgian-established VAT taxable persons must issue and receive structured electronic invoices for domestic B2B transactions over Peppol BIS in EN 16931 format; PDFs and paper are no longer legally valid. [globallawexperts.com], [edicomgroup.com]
A three-month tolerance period ended on 31 March 2026; from 1 April 2026, fines of €1,500 / €3,000 / €5,000 apply for first, second and subsequent breaches. [globallawexperts.com], [ey.com]
Non-established VAT-registered businesses are out of scope for issuing, but Belgian customers must still be able to receive; near real-time e-reporting to the tax authority is scheduled for January 2028, aligned with ViDA. [marosavat.com], [edicomgroup.com]

Article

The Belgian B2B e-invoicing mandate, enacted via the Programme Law of 22 December 2023 and implemented through the Royal Decree of 14 July 2025, requires structured invoices compliant with EN 16931, exchanged by default via Peppol BIS. FPS Finance’s 19 December 2025 clarification confirmed that the obligation binds only Belgian-established suppliers, and introduced a “fallback” rule allowing non-structured invoices where a recipient is temporarily technically unable to receive e-invoices. FPS BOSA, acting as Belgian Peppol Authority, continues to operate the Mercurius portal and the certified Access Point ecosystem; B2G invoices above €3,000 have been mandatory since 1 March 2024. From January 2028, periodic customer listings will be replaced by near real-time transmission of invoice data — a 5-corner Peppol-based reporting model directly informed by ViDA. [globallawexperts.com], [marosavat.com] [peppol.org], [bosa.belgium.be] [edicomgroup.com]

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