Ahead of ViDA: Belgium Formalises Dual Near Real-Time VAT E-Reporting from 2028

The positive side: real simplification

• Abolition of the annual client listing. For every taxpayer subject to e-reporting, the recurring annual customer-listing obligation disappears — a genuine reduction in periodic compliance work.
• ViDA readiness. Because the design is meant to align with VAT in the Digital Age, investment made now is partly reusable for the EU-wide Digital Reporting Requirements due July 2030 — if it stays on the EN 16931 minimum dataset without Belgian-specific extensions.
• Better data quality and faster processes. The digitised, near-real-time flow is intended to improve data reliability and, over time, make audits more efficient.

The burden side: what dual reporting imposes on businesses

• A new obligation on the purchase (customer) side: The most significant change is that every business becomes a reporter as a customer, not just as a supplier. The customer must retransmit invoice data the supplier has already reported — the administration receives “two identical data streams rather than two independent controls,” i.e. duplication without benefit.
• A five-day deadline that clashes with normal invoice cycles: Invoices arrive via multiple channels (Peppol, EDI, fallback, paper in transition), and standard triage, validation and dispute cycles “routinely exceed five days.” Businesses risk penalties for late or incomplete reporting of data they did not create and may legitimately be contesting.
• Systematic misalignment with the VAT return: Timing differences, disputed invoices, credit notes, retroactive price adjustments and rebates will “inevitably generate systematic discrepancies” between e-reported data and the periodical VAT return — producing a steady flow of reconciliation queries that raise compliance cost on both sides without improving audit quality.
• Higher IT and integration cost: Validating supplier data within the reporting window “without deep ERP integration” is not feasible for large business customers — so dual reporting drives a significant accounts-payable IT build, on top of the sales-side systems already adapted for the 2026 e-invoicing mandate.
• Triple reporting on cross-border / Article 194 flows: For non-established suppliers and reverse-charge chains, dual reporting of Article 194 transactions from 1 July 2028 means the same data could be reported three times — supplier e-reporting in its Member State, customer e-reporting in Belgium, and again via the EC Sales Listing under ViDA — contrary to the “report only once” principle
• Loss of EU harmonisation for multinationals: ViDA makes customer-side reporting optional, not mandatory. A Belgian mandate would set a precedent, undermine harmonisation, and force multinationals into country-specific designs for what should be a single European process.
• The timeline risk for everyone: The 1 January 2028 target is viewed as unrealistic — especially if the SAF-T package arrives in parallel as part of the anti-fraud measures. Businesses need “a minimum of one year’s lead time from the moment all rules and IT requirements are final and stable,” yet the implementing Royal Decree (dataset, deadlines, exceptions) is only expected early 2027, leaving under 12 months to build, test and go live.

Bottom line: for businesses generally, the reform delivers one clear win (the client listing goes), but the dual-reporting model shifts a substantial new near-real-time burden onto the customer/purchase side — tight deadlines, VAT-return mismatches, IT cost and triple reporting on cross-border flows — which is why the business community is pressing for supplier-only reporting while the draft is still with the DPA and Council of State.

Summary

• At the Council of Ministers of 18 July 2026, on a proposal by Finance Minister Jan Jambon, Belgium’s federal cabinet approved a pre-draft law amending the VAT Code to introduce mandatory near real-time e-reporting from 1 January 2028 and to abolish the annual customer listing for taxpayers subject to the new regime.
• The system is dual-sided: both supplier and customer must transmit key invoice data to the tax administration in near real time, building directly on the structured B2B e-invoicing mandate live since 1 January 2026. The design uses a 5-corner Peppol model, converting periodic reporting into continuous transaction-level data.
• The pre-draft now goes to the Data Protection Authority and the Council of State before Parliament, with publication expected in autumn 2026 and detailed rules by Royal Decree in early 2027. Belgium’s 2028 start places it ahead of the EU’s ViDA Digital Reporting Requirements scheduled for July 2030.

Extended article

Belgium has taken the decisive legislative step on the second phase of its VAT digitalisation programme. At a Council of Ministers held on 18 July 2026 under PM Bart De Wever, on a proposal by Finance Minister Jan Jambon, the cabinet approved a pre-draft law amending the VAT Code to introduce mandatory near real-time e-reporting and to abolish the annual list of taxable customers (klantenlisting). Until this decision, e-reporting from 2028 existed only as a commitment in the 2025–2029 coalition agreement.

The reform rests on three pillars. First, near real-time reporting on top of e-invoicing: since 1 January 2026 Belgian taxpayers must exchange structured e-invoices for domestic B2B transactions, and the draft requires certain mandatory invoice data to be reported almost immediately after issuance. Second, a dual-sided obligation: both supplier and customer must report, creating duties for both AR and AP teams. Third, abolition of the annual client listing for taxpayers in the new regime.

Technically, Belgium builds on the Peppol network anchored to EN 16931, moving toward a 5-corner model where invoice data flows to the administration in near real time. The sequencing is deliberate: structured B2B e-invoicing (from 1 January 2026, with fines of €1,500–€5,000 for repeated non-compliance after a Q1-2026 tolerance window), then e-reporting from 1 January 2028, converging in July 2030 with ViDA’s Digital Reporting Requirements. The pre-draft has been sent to the Data Protection Authority and the Council of State before Parliament; publication is expected in autumn 2026, with the granular dataset set by Royal Decree in early 2027. ERP and invoicing platforms already adapted for 2026 must next emit a defined subset of invoice data in near real time — on both sales and purchase sides — before the 2028 go-live.

External links

• RTC Suite — Belgium approves dual near real-time VAT e-reporting for 2028
• Fiscal Solutions — Belgium formalises dual near real-time VAT e-reporting from 2028

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