E-invoicing was only the beginning: Belgium plans near-real-time VAT reporting from 2028

Dual-Sided Digital Reporting via Peppol: Starting 1 January 2028, a Belgian draft law proposes that both suppliers and buyers must electronically report domestic B2B invoice data via the Peppol network within a maximum of five calendar days, moving from annual aggregate reporting to near-real-time invoice matching.
Abolition of the Annual Client Listing: The new regime replaces the traditional annual client listing for most domestic taxpayers (after the final 2027 listing due by 31 March 2028), while foreign businesses holding a Belgian VAT number generally remain subject to the annual listing through 30 June 2030 unless they voluntarily opt into electronic reporting.
Extended Scope and EU Law Debate: The mandate also covers transactions between members of a VAT unit and one-sided reporting by Belgian suppliers to foreign entities with a Belgian VAT number (even where structured e-invoicing is not mandatory), a broader scope that the Council of State questioned regarding its compatibility with EU VAT directives.

Click on the logo to visit the website

Belgium advances near-real-time VAT e-reporting for 2028

Summary

Belgium has moved its planned electronic VAT reporting regime into the parliamentary process, with a proposed start date of 1 January 2028. The measure builds directly on mandatory structured domestic B2B e-invoicing, which has applied since 1 January 2026, and would add near-real-time transmission of selected invoice data to the tax administration.
The proposed model is bilateral: both suppliers and customers would report data from structured electronic invoices. This allows the administration to compare both sides of a transaction. For taxpayers covered by the new obligation, electronic reporting is intended to replace the annual list of VAT-registered customers, while periodic VAT returns would continue.
The parliamentary and implementing process remains important because the final scope, reporting deadline, technical specifications and treatment of exceptions still require confirmation. Businesses should nevertheless begin mapping invoice data, Peppol connectivity, corrections, self-billing and reconciliation controls because the reporting layer will rely on the quality of existing structured invoice data.

Extended article

Belgium is progressing from mandatory B2B e-invoicing to a broader digital VAT control model. The proposed legislation would introduce electronic reporting of selected data contained in structured invoices from 1 January 2028. This is a separate obligation from e-invoicing: the invoice continues to move between supplier and customer, while prescribed data would also be transmitted to the Belgian tax administration.

A distinguishing feature is bilateral reporting. Both the issuer and the recipient of a structured invoice would transmit transaction information, enabling automated comparison of sales and purchase data. The proposal also links the new system to administrative simplification by removing the annual customer listing for taxpayers within scope. Periodic VAT returns would remain because invoice reporting does not capture every adjustment and transaction needed to calculate the final VAT position.

For businesses, this is primarily a data-and-controls programme rather than a narrow tax filing change. ERP and billing systems will need consistent VAT identifiers, invoice references, tax codes and correction logic. Accounts payable will also become part of the reporting control environment because received invoice data may have to be transmitted and reconciled. Special attention is needed for credit notes, disputed invoices, self-billing and documents treated as equivalent to structured invoices.

The legislation and implementing measures are not yet final. Companies should therefore avoid locking down technical builds prematurely, but they can already assess data completeness, Peppol coverage, process ownership and the ability to reconcile invoice-level information to VAT returns. The 2026 e-invoicing implementation should be treated as the foundation for the 2028 reporting obligation, not as a stand-alone project.

External references: Belgian e-reporting Bill overview | KPMG analysis of the Belgian proposal | Deloitte VAT alert