Mandatory electronic invoicing in Belgium

Author: Ben Pinnock, Senior Manager, Global Business Solutions

Since 1 January 2026, structured electronic invoicing has been mandatory for most domestic B2B transactions between VAT-registered businesses established in Belgium. The requirement is now in force.

The information below summarises the current position, the businesses and transactions in scope, and the practical steps still required to remain compliant.

Why was this introduced?

Electronic invoicing was introduced to streamline and modernise invoicing processes in Belgium. It is intended to support faster, more accurate and efficient transactions while improving transparency, traceability and security.

The Belgian rules form part of the wider move towards digital VAT compliance across the EU, including the VAT in the Digital Age (ViDA) reforms. Belgium’s current requirement concerns structured electronic invoicing. In July 2026, the Belgian Council of Ministers approved a preliminary law with the aim of achieving near real-time VAT e-reporting from 1 January 2028; however, this remains a proposal and is subject to the legislative process.

Who does this impact?

The obligation applies broadly to domestic B2B transactions between VAT-registered businesses established in Belgium. In general, it applies where:

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).

Certain companies with a Belgian VAT number are exempt; however, therefore, we recommend seeking specific guidance as to how this may or may not affect your business if you are uncertain.

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

Businesses that are not established in Belgium and do not have a Belgian fixed establishment are not currently required to issue or receive structured electronic invoices under the Belgian B2B mandate merely because they hold a Belgian VAT registration or use a fiscal representative.

However, such foreign companies can opt to voluntarily send and/or receive electronic invoices in the Peppol format.

What does this regulation involve?

Under the rules now in force, affected businesses must issue and be able to receive structured electronic invoices for in-scope B2B transactions.

A PDF sent by email or a paper invoice is not by itself a compliant structured electronic invoice for an in-scope transaction. A PDF or paper copy may still be supplied as a supplementary, human-readable copy.

When invoicing private individuals (B2C), the obligation does not currently apply; therefore, paper and PDF invoices can still be issued in these instances.

Separate electronic invoicing requirements have applied to relevant public procurement transactions (B2G) for contracts published from 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).

Businesses within scope should therefore already be able to send and receive structured e-invoices through the Peppol network or through another agreed solution that complies with the European standard and processes those invoices through their accounting or ERP systems.

What is the Peppol standard?

Also known as Pan-European Public Procurement Online (Peppol), this is a network standard which was introduced for the purposes of sending and receiving electronic documents, such as invoices. The principal aim of using the Peppol standard is to ensure invoicing between businesses is consistent and transparent.

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 to be working with accounting software which is compatible with Peppol or to 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.

It is possible to implement an alternative system other than Peppol if it meets the European standards in this respect and the parties involved agree to this; however, any alternative options from Peppol should be approached with caution.

Are there any VAT implications?

Businesses should ensure that invoices supporting Belgian VAT recovery meet the applicable invoicing requirements. For transactions within the mandate, the required document is a compliant structured electronic invoice. Transactions outside the mandate, including relevant B2C transactions, continue to follow the ordinary Belgian VAT invoicing rules.

Next steps?

Businesses should review whether all relevant Belgian entities and establishments are correctly registered on Peppol, confirm that both incoming and outgoing invoice flows are working, and retain evidence of any technical issues and remedial action. The general administrative tolerance period ended after the first three months of 2026, so businesses should address any remaining gaps promptly.

If you would like to review how the rules apply to your business, resolve implementation issues or prepare for the proposed 2028 e-reporting requirements, please get in touch.