Electronic invoice in Belgium
Comprehensive guide to mandatory B2B electronic invoicing in Belgium – Legal framework, obligations, and practical implementation from January 1, 2026
Overview
Mandatory structured B2B e-invoicing has been in force in Belgium since 1 January 2026. Every VAT-liable business established in Belgium must issue and receive structured electronic invoices for domestic B2B transactions. The legal basis is the Law of 6 February 2024 amending the VAT Code.
Belgium deliberately chose a decentralised model: invoices travel over the Peppol network using the four-corner model, with no government platform in the transmission path and no clearance step. A near real-time reporting layer follows in 2028.
Established in Belgium
is the test for scope — a VAT number alone is not enough
Peppol BIS 3.0
the default format and transmission route by law
10 years
retention period for invoices and accounting records
Timeline
Unlike most other countries, Belgium introduced the B2B obligation in a single step rather than staggering it by company size. The concession was on enforcement instead: a three-month tolerance window before the fines began.
Already in force
2017 – 2023
Phased B2G rollout
Flanders led from 2017, Brussels followed in November 2020 and Wallonia in January 2022. At federal level the Royal Decree of 9 March 2022 phased the supplier obligation in by contract value.
6 February 2024
Law amending the VAT Code
The legal basis for mandatory domestic B2B e-invoicing is published, giving businesses close to two years to prepare.
1 January 2026
B2B e-invoicing becomes mandatory
All VAT-liable businesses established in Belgium must issue and receive structured e-invoices for domestic B2B transactions. A PDF sent by email no longer satisfies the obligation.
1 April 2026
End of the tolerance period
Enforcement begins. From this date the tax administration applies graduated fines where the obligation is not met.
Still ahead
1 January 2028
Near real-time e-reporting
A reporting layer is added on top of the invoice exchange, moving Belgium to a Peppol five-corner model. It will progressively replace the annual client listing.
1 July 2030
ViDA cross-border reporting
Belgium will implement the EU Digital Reporting Requirement for intra-community B2B transactions and align it with the national obligations already in place.
The 2028 step is a genuine change in kind, not just a new deadline. Today the tax administration sees nothing of a domestic invoice; from 2028 it receives the data. Anyone building a connection now should already ask their provider how the fifth corner will be handled.
Who is in scope
Scope depends on three things: the supplier, the customer and the transaction. All three need to be checked — being in scope as a business does not automatically put every transaction in scope.
Suppliers who must issue
—Taxable persons established in Belgium
—Belgian permanent establishments of foreign entities
—Members of Belgian VAT groups
—Taxable Belgian entities under the special agricultural VAT scheme
What falls outside
Foreign entities merely registered for Belgian VAT without a permanent establishment
Entities carrying out only activities exempt under Article 44 of the Belgian VAT Code
Bankrupt entities, and businesses under the special flat-rate scheme (which is being abolished in 2028)
Transactions with end consumers (B2C)
Which transactions are covered
—All local B2B transactions subject to Belgian VAT, including supplies under the local reverse charge
—Not covered: intra-community supplies and services taxed in another EU member state
—Not covered: transactions exempt under Article 44 of the VAT Code
For foreign businesses
A Belgian VAT number on its own does not bring you into scope — what matters is a permanent establishment in Belgium. That said, preparing to receive is worthwhile in any case: your Belgian suppliers now issue structured invoices as standard, and receiving them on paper is no longer the default.
B2G and Mercurius
Belgium was an early mover in public-sector e-invoicing. The federal law on public procurement of 7 April 2019 transposed Directive 2014/55/EU, and the Royal Decree of 9 March 2022 phased in the supplier-side obligation by contract value.
€215,000 and abovee-invoice required for tenders published from 1 November 2022
€30,000 and abovefrom 1 May 2023
Below €30,000from 1 November 2023
Below €3,000exempt from the e-invoicing obligation
Mercurius
The central mailroom for the public sector, fully aligned with Peppol. It spares suppliers from setting up bilateral connections with every public body and offers track-and-trace plus manual submission through a web portal.
Hermes
A temporary safety net: it converts structured e-invoices into a readable form for recipients not yet equipped to process them. Designed to be phased out as digital maturity increases.
Both platforms run exclusively on the Peppol interoperability model, which is why the B2G and B2B routes converge technically. If you already invoice Belgian public bodies over Peppol, the B2B mandate meant little new infrastructure.
Formats and standards
The governing standard is EN 16931. Belgium uses the Peppol BIS Billing 3.0 CIUS and has deliberately not created a national CIUS of its own — a decision that keeps cross-border exchange simple.
Peppol BIS Billing 3.0 (UBL 2.1)
The default format and the default route. No prior agreement between the parties is needed — every business in scope is reachable this way.
Alternative formats
Other formats are permitted only by mutual agreement and only where they comply with EN 16931. The UN/CEFACT CII syntax is likewise supported through Peppol.
A detail worth knowing
No party may impose an alternative format on a trading partner. Even where an alternative is agreed, the Peppol route must remain possible as the fallback. In practice this means: if in doubt, Peppol — and a counterparty demanding a proprietary format cannot insist.
A PDF is not an electronic invoice for these purposes. It may accompany the structured file as a human-readable rendering, but it does not discharge the obligation.
The Peppol model
Belgium runs the classic four-corner model: the supplier passes the invoice to its access point, which routes it across the Peppol network to the customer's access point, which delivers it into the customer's system. There is no government platform in the path and no clearance step — a materially lighter design than the central systems used in Poland or Italy.
Exchange with European partners
The same connection serves every Peppol country — no separate link per trading partner.
Automatic format validation
Access points check the invoice against the specification before it enters the network.
Secure transmission
Encrypted communication between access points and non-repudiation of delivery.
One route for B2B and B2G
Public bodies and private customers are reached through the same connection.
Addressing uses the recipient's Peppol identifier, normally derived from the Belgian enterprise number or VAT number. Whether a partner is reachable can be checked in the Peppol directory before you send.
E-reporting from 2028
From 1 January 2028 Belgium adds a reporting layer on top of the invoice exchange. Invoice data will flow to the tax administration (FPS Finance) in near real time, moving the country from a four-corner to a five-corner model — with the tax administration as the fifth corner.
Reporting is planned on both sides of the transaction, supplier and customer
The annual client listing is to be replaced over time by the new reporting
The system will again build on Peppol specifications, limiting the impact on businesses already connected
That last point is the reassuring one: if the connection you build now is a genuine Peppol integration rather than a workaround, the 2028 step should be an extension rather than a second project.
Penalties
A tolerance period applied until 31 March 2026. Since 1 April 2026 the tax administration has been enforcing graduated fines for failing to issue structured invoices where the obligation applies.
€1,500
First offence
€3,000
Second offence
€5,000
Third offence
The escalation applies to repeat offences within three months, so the amounts add up quickly for a business still invoicing outside the system. On top of the fine come the practical consequences: an invoice that does not meet the requirements puts your customer's input VAT deduction at risk.
Tax incentives
Alongside the obligation, Belgium introduced financial support for the transition. Both measures are worth checking with your accountant — they are frequently overlooked.
120%
Increased cost deduction
For small SMEs and the self-employed using a subscription model, for tax periods 2024 to 2027. The additional e-invoicing cost must be shown separately on the software invoice to qualify.
20%
Digital investment deduction
The investment deduction for digital investments was raised from 1 January 2025, covering hardware and software acquired for e-invoicing compliance.
For a small business the combined effect can offset a meaningful share of the first-year cost. The separate-line requirement on the software invoice is the detail that most often causes the deduction to be missed.
Retention
Invoices must be retained in Belgium for ten years. Because the mandate is decentralised, no government system stores them for you — retention is entirely your responsibility, whether handled in-house or by a provider.
The structured XML file is the original and must be archived unchanged — a PDF rendering does not replace it
Authenticity of origin, integrity of content and legibility must be assured throughout the period
Invoices must be produced in readable form at short notice during an audit
This is a point where the Belgian model differs from Poland's, for instance, where the state platform archives on your behalf. In Belgium, deciding who stores the files — your provider, your DMS or a specialist archiving service — is part of the implementation, not an afterthought.
How we help
As a certified Peppol Access Point we connect your systems to the Belgian mandate — and to the rest of Europe through the same link:
Sending and receiving through a certified Peppol Access Point
Peppol BIS Billing 3.0 (UBL 2.1) and UN/CEFACT CII
Validation against EN 16931 before transmission
Format conversion from ERP, CSV and IDoc data
B2G submission to Belgian public bodies via Mercurius and Peppol
Integration via API, SFTP and CSV
Traceable status and error feedback
A connection built to extend to the 2028 reporting layer
Frequently asked questions
Can I still send PDF invoices?
Not for domestic B2B transactions in scope. A PDF sent by email or through a portal does not satisfy the obligation, even when digitally signed. You may continue to produce a PDF as a human-readable rendering alongside the structured file. For B2C invoices and for transactions outside the scope, PDF remains acceptable.
What if my counterparty is not ready to receive e-invoices?
Since 1 January 2026 every business in scope has been legally required to be able to receive structured invoices — being unprepared is their compliance problem, not a valid reason for you to fall back to PDF. The Hermes platform exists as a temporary safety net, converting structured invoices into a readable form for recipients who are not yet equipped. It is explicitly a transitional measure and is designed to disappear.
Are small businesses covered too?
Yes. Belgium did not stagger the mandate by company size — it applies to every VAT-liable business established in Belgium, including the self-employed. Businesses under the special flat-rate scheme and those carrying out only Article 44 exempt activities are outside the scope. Low-cost and free Peppol on-ramps are available for very small volumes, and the 120% cost deduction is aimed precisely at this group.
Does the mandate apply to foreign businesses with a Belgian VAT number?
No — a Belgian VAT registration alone does not bring you into scope. The test is whether you have a permanent establishment in Belgium that is involved in the transaction. Belgian permanent establishments of foreign companies are fully in scope. Being able to receive is worthwhile regardless, since your Belgian suppliers now issue structured invoices by default.
Are cross-border transactions covered?
No. Intra-community supplies and services taxed in another EU member state fall outside the Belgian mandate. Local reverse-charge supplies, by contrast, are covered. From July 2030 the EU-wide ViDA reporting will apply to intra-community B2B transactions.
Can a customer require a different format from Peppol?
They can propose one, but they cannot impose it. Alternative formats are permitted only by mutual agreement and only where they comply with EN 16931. Regardless of any agreement, the Peppol route must always remain available as the default. If you cannot reach agreement, Peppol applies.
Who has to archive the invoices?
You do. Belgium's decentralised model means no state platform stores invoices on your behalf. The retention period is ten years, and the structured XML file is the original that must be kept. Where a provider handles storage technically, legal responsibility still rests with your business.
Summary
Belgium is among the first EU countries to have mandatory B2B e-invoicing genuinely live. The obligation took effect on 1 January 2026 for all VAT-liable businesses established in the country, and enforcement began on 1 April 2026 once the tolerance period ended.
The chosen architecture is notably light: a decentralised Peppol four-corner network, the unmodified European standard, no national CIUS and no clearance step. For businesses already exchanging over Peppol, the mandate largely meant switching on an existing capability rather than building a new one.
The next milestone is 2028, when near real-time reporting adds a fifth corner and replaces the annual client listing. Because it reuses the Peppol specifications, businesses with a proper integration in place should face an extension rather than a second implementation project.
Resources
einvoice.belgium.be – the official e-invoicing portal
Government guidance and an extensive FAQ on the B2B and B2G obligations
Mercurius – the public sector portal
Track and trace plus manual submission for invoices to Belgian public bodies
Hermes – the transitional conversion service
How structured invoices reach recipients who are not yet equipped
BOSA – Peppol in Belgium
The responsible federal authority, with published adoption statistics
European Commission – eInvoicing in Belgium
Country factsheet covering the legal position, operating model and scope details
Peppol Directory
Check whether a trading partner is reachable on the network
invoice-portal.be
More on invoicing in Belgium
