Mandatory Electronic Invoicing in Belgium: Timeline and Preparation

Belgium is firmly committed to going digital on tax matters. Since 1 January 2026, structured electronic invoicing has become mandatory for B2B transactions between VAT-registered businesses established in Belgium. This reform, introduced by the law of 6 February 2024 amending the VAT Code, is reshaping the invoicing processes of every Belgian company. Here is everything you need to know to become compliant.

The legal framework for electronic invoicing in Belgium

Reference texts

• Law of 6 February 2024 amending the VAT Code with regard to electronic invoicing (Belgian Official Gazette of 5 March 2024)
• Article 53, §2 of the VAT Code (as amended): requires structured electronic invoices to be issued for domestic B2B transactions
• European Directive 2014/55/EU: the European framework for electronic invoicing in public procurement
• European standard EN 16931: the technical standard for the semantic format of electronic invoices
• ViDA Regulation (VAT in the Digital Age): the future harmonised European framework for electronic invoicing and real-time digital reporting

Why this reform?

FPS Finance is pursuing several objectives:

1. Fighting VAT fraud: the Belgian "VAT gap" (the difference between VAT theoretically due and VAT actually collected) is estimated at around EUR 3.1 billion a year according to the European Commission
2. Reducing the administrative burden on businesses: a paper invoice costs an average of EUR 11 to process (printing, postage, data entry), against EUR 1 to 3 for an electronic invoice
3. Aligning Belgium with pioneering countries (Italy since 2019, France from 2026, Germany from 2028)
4. Laying the groundwork for real-time digital reporting under the EU's ViDA regulation

The compliance timeline: what applies now

Since 1 January 2026: the general B2B obligation

The obligation covers every VAT-registered business established in Belgium for its domestic B2B transactions:

Exceptions and special cases

Certain situations receive specific treatment:

• Businesses under the VAT exemption scheme (turnover < EUR 25,000): exempt from the obligation to issue electronic invoices, but must be able to receive them
• Businesses under the flat-rate scheme: temporarily exempt (transitional provision until 1 January 2028)
• B2C transactions: no obligation to issue structured electronic invoices (paper or PDF invoices remain allowed)
• Intra-Community and international transactions: subject to future ViDA rules (expected 2028–2030)
• Credit notes: must also be issued in the structured electronic format
• The public sector: electronic invoicing to Belgian public authorities has already been mandatory since 1 November 2022 via the Mercurius platform

Looking ahead: the ViDA regulation

The European ViDA (VAT in the Digital Age) regulation, adopted in 2024, provides for a gradual extension:

• 2028: Member States may make electronic invoicing mandatory for intra-Community transactions
• 2030: mandatory real-time Digital Reporting Requirements for intra-Community transactions
• 2032: full harmonisation at European level

What counts as a structured electronic invoice?

What is accepted, and what is NOT

It is essential to understand the difference:

Features of a compliant electronic invoice

A structured electronic invoice must:

1. Be in XML format compliant with the UBL 2.1 (Universal Business Language) syntax or UN/CEFACT CII
2. Comply with the EN 16931 semantic standard: a set of mandatory fields and validation rules
3. Be transmitted via the Peppol network: a secure network for exchanging business documents
4. Be automatically readable by accounting software without human intervention
5. Contain all the mandatory particulars required by the Belgian VAT Code (article 5 of Royal Decree No. 1)

Mandatory particulars on a Belgian invoice

A reminder of the mandatory particulars (article 5 of the Royal Decree of 29 December 1992, No. 1):

The Peppol network: how it works

Network architecture

Peppol (Pan-European Public Procurement OnLine) is a secure international network for exchanging electronic business documents. It works on a "four-corner" model:

Issuer → Issuer's access point → Peppol network → Recipient's access point → Recipient

1. The issuer creates the invoice in their software
2. The issuer's access point (a certified Access Point) sends the invoice onto the Peppol network
3. The Peppol network routes the invoice to the right recipient using their Peppol identifier
4. The recipient's access point receives the invoice and forwards it to the recipient
5. The recipient receives the invoice directly in their accounting software

The Belgian Peppol identifier

In Belgium, the Peppol identifier is based on the CBE company number (Crossroads Bank for Enterprises):

• Format: 0208:BE0123456789 (prefix 0208 for CBE numbers)
• Registration: via your invoicing software or your Peppol access point
• Directory: verifiable via Peppol's SMP (Service Metadata Publisher)

Certified Peppol access points in Belgium

Several providers are certified as Peppol access points in Belgium:

How to prepare: a step-by-step guide

Step 1: Assess your current situation

Answer the following questions:

• Which invoicing software do you currently use?
• Is this software Peppol/UBL compatible?
• How many B2B invoices do you issue per month?
• How many B2B invoices do you receive per month?
• Are your main clients and suppliers already on Peppol?

Step 2: Choose your technical solution

Option A: Invoicing software with Peppol built in

This is the simplest solution for SMEs and self-employed people:

Option B: Connecting via a Peppol access point

For businesses that want to keep their current software (ERP, custom-built software):

1. Subscribe to a certified Peppol access point
2. Integrate the access point's API into your system
3. Configure invoice generation in the UBL format

Estimated cost: EUR 50 – 500/month depending on invoice volume

Option C: An intermediary platform (CodaBox)

CodaBox offers a "digital mailbox" service:

• You receive and send your invoices via CodaBox
• CodaBox manages the Peppol connection
• Your accountant has direct access

Step 3: Register on Peppol

1. Activate your Peppol identifier via your software or access point
2. Verify your registration in the Peppol directory (directory.peppol.eu)
3. Share your Peppol identifier with your clients and suppliers
4. Test sending and receiving with a business partner

Step 4: Adapt your internal processes

• Approval workflow: decide who approves incoming invoices
• Archiving: electronic invoices must be kept for 7 years (article 60 of the VAT Code) in a format that guarantees their integrity and legibility
• Reconciliation: automate matching between invoices, purchase orders and deliveries
• Training: train your administrative and accounting staff

Step 5: Communicate with your partners

• Tell your clients and suppliers your Peppol identifier
• Ask for your partners' Peppol identifiers
• Agree a switchover date
• Plan a period of double sending (electronic + PDF) if needed during the transition

Concrete benefits of electronic invoicing

Financial gains

Concrete example: a Walloon SME issuing 200 B2B invoices a month and receiving 150 could save between EUR 30,000 and 60,000 a year by switching to structured electronic invoicing.

Operational gains

• Automated bookkeeping: XML data is imported automatically into the accounting software, eliminating manual data entry
• Automatic reconciliation: invoices are automatically matched against purchase orders
• Real-time tracking: you know instantly whether your invoice has been received and accepted
• Fewer disputes: fewer errors mean fewer challenges
• Easier VAT compliance: structured data simplifies VAT returns

Environmental gains

FPS Finance estimates that widespread electronic invoicing in Belgium could save:

• 150 million sheets of paper a year
• 3,000 tonnes of CO2 a year (postal transport)
• Thousands of litres of ink and toner

Frequently asked questions

"I am self-employed and issue 5 invoices a month, does this affect me?"

Yes, if you are VAT-registered and you invoice other Belgian VAT-registered businesses. You must issue structured electronic invoices via Peppol. Affordable solutions exist (Banqup, Dexxter, Billit) from EUR 10-15/month.

"My client refuses to receive an electronic invoice, what should I do?"

Since 1 January 2026, a VAT-registered client in Belgium is required to accept structured electronic invoices. They can no longer refuse. If your client is not yet equipped, point them towards a free or low-cost solution for receiving their invoices.

"Can I keep sending a PDF alongside it?"

Yes, you can send a PDF in addition to the structured electronic invoice to make it easier for humans to read. But a PDF alone no longer has legal value for domestic B2B transactions between Belgian VAT-registered businesses.

"How should I archive my electronic invoices?"

Article 60 of the VAT Code requires a 7-year retention period. Invoices must be stored in a format that guarantees their integrity, authenticity and legibility throughout that period. Archiving within the invoicing software or on a secure cloud is acceptable.

Penalties for non-compliance

The VAT Code provides for the following penalties:

Note: FPS Finance has indicated it will apply a tolerance period for the first months of 2026, favouring support over sanctions. This tolerance does not remove the obligation to become compliant.

Useful resources

Conclusion

Mandatory electronic invoicing has been a reality in Belgium since 1 January 2026. Far from being a mere administrative constraint, it is an opportunity to modernise your processes, cut your costs and improve your cash flow through faster payments. The technical solutions are mature and accessible, even for the smallest businesses. Do not wait for an FPS Finance penalty: get yourself a Peppol-compatible software solution now, register your identifier in the directory, and start issuing your invoices in the structured format. Your accountant will thank you.