As of January 1, 2026, Belgium will implement mandatory B2B e-invoicing for nearly all businesses. This legislation marks a significant step in the country's digital transformation journey and aims to enhance tax efficiency, reduce tax evasion, and streamline business processes.
This report is your go-to guide for understanding the new e-invoicing legislation, covering all the essential requirements, timelines, and benefits for businesses.
Background
The Belgian government has been actively promoting e-invoicing for several years. With mandatory B2G e-invoicing already in place for public contracts above €3,000 since March 1, 2024, the recent legislation extends this mandate to the B2B sector, aligning with broader European Union initiatives to standardize e-invoicing practices across member states.
Belgium offers a variety of invoicing options, including paper, PDF, electronic, and portal key-in invoices. But with the new rules, businesses will need to switch to structured electronic invoices that can be automatically processed.
You can still use PDFs until December 31, 2025, but starting January 1, 2026, only structured electronic invoices in the Peppol-BIS format will be the way to go.
Key requirements for businesses
To meet the new e-invoicing rules, businesses should follow these guidelines:
- Issuers of e-invoices must:
- Be VAT established in Belgium, including foreign entities with a VAT fixed establishment.
- Be VAT registered in Belgium, including those under the small enterprises exemption or agricultural “forfait” regime.
- Not be in a state of bankruptcy or exclusively conducting exempt transactions under Article 44 of the Belgian VAT Code.
- If operating in the Wallonia region, include a Bank Identity Statement on invoices if the issuer's bank account details are not in the regional database. - Recipients of e-invoices must:
- Be VAT registered in Belgium and obligated to share their VAT number with the supplier. This includes foreign entities and members of a VAT group.
- Accept the electronic invoice, as refusal is not permitted. - The object of the e-invoice must:
- Be a supply of goods or services that is VAT located in Belgium.
- Not be exempt under Article 44 of the Belgian VAT Code, with some exceptions. - VAT Groups:
A member of a VAT group must issue invoices or specific documents for transactions with other members of the same VAT group in accordance with the terms and conditions laid down for structured electronic invoices if the issuer would have been required to issue a structured electronic invoice for that transaction. - No reporting of invoice data:
Unlike some other EU countries, the Belgian e-invoicing mandate does not require businesses to report invoice data to the tax authorities.
Timeline
The key dates for the implementation of the e-invoicing legislation are as follows:
- March 1, 2024:
Mandatory B2G e-invoicing for all federal public contracts above €3,000. - January 1, 2026:
Mandatory B2B e-invoicing for nearly all B2B transactions between VAT-liable Belgian enterprises. This date reflects a key shift from a previously planned phased implementation, giving businesses more time to prepare but requiring them to be fully compliant by the deadline. - January 1, 2028:
Anticipated introduction of a 5-corner Peppol-model, including near real-time e-reporting of B2B domestic transactions to the tax administration. This 5-corner model differs from the current 4-corner model by adding a direct connection between businesses and the tax administration for real-time reporting of invoice data. This is expected to increase transparency, reduce the VAT gap, and potentially pose challenges for businesses in terms of data management and reporting.
It is important to note that these rules could be further amended to ensure full compatibility with final rules adopted at the EU level.
Benefits of e-Invoicing
The transition to e-invoicing offers several benefits for businesses:
- Cost Reduction: Eliminates expenses related to paper, printing, and postage.
- Process automation and efficiency: Automates invoice processing, reducing manual tasks and errors.
- Enhanced cash flow: Accelerates payment cycles and improves cash flow forecasting.
- Improved accuracy: Reduces errors associated with manual data entry.
- Increased security: Enhances data security and reduces the risk of fraud.
- Environmental benefits: Reduces paper consumption and promotes sustainability.
- Tax Incentives:
The Belgian government is offering a temporary boost with a 120% cost deduction in income taxes for expenses related to billing packages that support e-invoicing, along with any consulting costs that come with it.
The investment deduction for digital investments will be increased to 20% from January 1, 2025.
The extra cost incurred for an existing software subscription due to e-invoicing is eligible for the increased deduction of 120%, provided it is indicated separately on the invoice.
Consequences for non-compliance
Although the exact penalties for not following the e-invoicing rules aren't clearly laid out, it's important for businesses to be mindful of the possible outcomes:
- Financial penalties:
May be imposed for issuing non-compliant invoices. These can include proportional penalties amounting to 200% of the VAT due for serious infractions like non-issuance or incorrect invoices, and non-proportional penalties ranging from €50 to €5,000 for non-compliance with invoicing requirements. - VAT recovery issues:
Customers may face challenges recovering VAT if they do not receive correct e-invoices. - Payment delays or non-payment:
Non-compliant invoices may be refused by customers, impacting cash flow. - Fines for non-issuance:
If an e-invoice is not issued when required, authorities may consider it as no invoice issued, leading to fines of up to €5,000 per invoice. - Additional penalties:
Customers may be denied the right to recover VAT, and penalties of 5-10% of the VAT due plus 8% annual interest may apply.
Challenges and considerations
While e-invoicing offers numerous benefits, businesses may face challenges during the transition:
- System integration: Integrating e-invoicing systems with existing ERP systems can be complex and require technical expertise.
- Staff training: Adequate training is crucial to ensure staff can effectively use new e-invoicing systems and processes.
- Data security: Businesses must implement robust security measures to protect sensitive financial data in electronic format.
- Choosing the right solution: Selecting an e-invoicing solution that meets specific business needs and ensures compliance with Belgian legislation is essential.
Here are some helpful tips for businesses to tackle these challenges:
- Plan ahead: Develop a clear e-invoicing implementation plan with timelines and resource allocation.
- Seek expert advice: Consult with e-invoicing specialists or software providers to ensure proper system integration and compliance.
- Invest in training: Provide comprehensive training to staff on new systems and processes.
- Prioritize data security: Implement strong security measures and data encryption to protect sensitive information.
E-Invoicing standards
Belgium has adopted the Peppol network as the preferred platform for e-invoicing. Peppol is an international, open network that facilitates the secure and standardised exchange of electronic documents, ensuring interoperability between different systems. Peppol compliance is crucial for seamless e-invoice exchange and interoperability with other businesses and government systems.
The standard format for e-invoices in Belgium is Peppol BIS 3.0, which aligns with the European standard EN 16931. This format ensures that e-invoices can be easily exchanged across borders within the EU. While Peppol is encouraged, businesses can use other systems compliant with the European EN 16931 standard through mutual agreement.
Key Takeaways:
- E-invoicing is mandatory in Belgium for nearly all B2B transactions from January 1, 2026.
- Businesses must use the Peppol network and Peppol BIS 3.0 format, although alternative compliant systems are possible with mutual agreement.
- Real-time e-reporting is expected to be introduced in 2028.
- E-invoicing offers numerous benefits, including cost savings, increased efficiency, and improved accuracy.
- The Belgian government provides tax incentives to encourage e-invoicing adoption.
Recommendations for businesses:
- Assess current systems and choose compatible software.
- Train staff on new e-invoicing processes.
- Implement robust data security measures.
- Plan ahead and seek expert advice if needed.
- Stay informed about updates to the legislation.
Early adoption and proactive measures, including participation in enablement campaigns, will enable businesses to capitalize on the opportunities presented by this digital transformation initiative.
Automate your invoice handling with Compello and PEPPOL
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This high automation level reduces manual tasks, improving efficiency and freeing resources for strategic activities, positioning businesses as digital transformation leaders.
Our services extend beyond a standard access point, including:
- Format conversions
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- Quality control
- Archiving of invoice requirements
- A service for receiving, scanning, and interpreting paper and email invoices.
Ready to automate?
Prepare for Belgium's PEPPOL mandate by January 2026. Connect with our advisors today for a chat!
