Mandatory electronic invoicing in Belgium

Who does this impact?

This affects almost all VAT registered businesses engaged in (business to business) B2B transactions in Belgium where the following conditions are fulfilled:

• supplier and customer are established and VAT registered in Belgium
• supply is subject to Belgian VAT or exempt (other than supplies exempt according to Article 39bis or 44 of the Belgian VAT Code).

Some companies with a Belgian VAT number are exempt. If you're unsure how this affects your business, seek specific guidance.

Will this impact foreign companies without a fixed establishment in Belgium?

However, these companies can choose to send and/or receive electronic invoices in the Peppol format.

Affected businesses must issue structured electronic invoices for B2B transactions. PDF or paper invoices for these transactions will no longer be legally compliant, though you can still however send a PDF or paper copy as a supplementary service to the customer.

When invoicing private individuals (B2C), the obligation doesn't currently apply, so paper and PDF invoices can still be issued.

This requirements for electronic invoices have already been in place for transactions with governments (B2G) since 1 March 2024.

What is an electronic invoice / e-invoicing?

E-invoicing is the digital exchange of invoices between suppliers and customers, which are shared across a secure platform. The electronic file containing the electronic invoice will need to:

• meet the same legal requirements as a paper invoice
• contain a fixed / mandatory format, i.e. an XML document (invoices without the required information cannot be sent)
• guarantee the identity of the sender and its content (changes are impossible)
• is readable by both a machine and a human (up-to-date accounting packages can read and process the information automatically).

As a result of the new regulations, VAT persons should therefore be able to receive and send e-invoices by means of an Peppol network, and be able to create, read and process e-invoices via their ERP / accounting package.

What is the Peppol standard?

Pan-European Public Procurement Online (Peppol) is a network standard for sending and receiving electronic documents, such as invoices. It ensures consistent and transparent invoicing between businesses.

To send or receive an electronic invoice via the Peppol network, the enterprise must
be connected to an Access Point of the Peppol network. To achieve this, you would need either be working with an accounting software which compatible with Peppol or utilise specific software which is available with the sole purpose of sending and receiving e-invoices. The Belgian government maintains a list of compliant software applications (note these are only available in Dutch). A full list of Peppol compliant software can be found on the Peppol.org website.

While you can use alternative systems to Peppol if they meet European standards and all parties agree, approach them with caution.

Are there any VAT Implications?

Starting January 1, 2026, you can only deduct Belgian VAT for invoices that comply with the new regulations. For transactions that fall outside the obligations, such as private invoices (B2C), you can still apply VAT deductions based on compliant paper invoices.

Next steps?

We recommend preparing your business for these changes as soon as possible, beginning by clearly understanding if / how this specifically affects your business, then ensuring the appropriate software is selected / implemented, employees are appropriately trained, and also utilising this time to check the correct VAT treatment of your invoices.

If you would you like to know more information or have questions about how to prepare for these changes, please feel free to get in touch with our specialists, who are ready to provide the necessary support to ensure a smooth transition for your business.