The implementation of B2B electronic invoicing in Belgium is now a reality. Following a period of several months, the mandatory use of structured electronic invoicing has been implemented for virtually all transactions between Belgian companies that are subject to VAT, with effect from 1 January 2026.
Furthermore, resident companies are now permitted to utilise the accounting software programmes that have been published by the Federal Public Service Finance (FPS), a development which will also facilitate the exchange of invoices in PEPPOL format.
Currently, the Belgian B2B e-invoicing system uses a PEPPOL-based four-corner model, in which structured electronic invoices are exchanged between the sender and the recipient through their respective service providers.
The obligation to issue structured electronic invoices does not apply to B2C transactions.
Furthermore, particular emphasis is placed on the structured electronic invoice format in accordance with the EN 16931 standard, enabling automated and electronic processing. As a result, invoices must be issued in PEPPOL BIS format.
If either the sender or the recipient is identified in a country outside Belgium, e-invoicing is subject to the conditions applicable to cross-border transactions. Where appropriate, the format and exchange mechanism may be determined by agreement between the sender and the recipient.
Belgium moves towards electronic reporting of invoicing data
Following the introduction of mandatory B2B e-invoicing, Belgium is moving towards the next stage of its digital tax compliance model: the implementation of an electronic reporting system for invoicing data.
The Council of Ministers has approved a preliminary draft law to amend the VAT Code and introduce an obligation to electronically report certain mandatory invoice data in near real time. The model provides for bilateral reporting, meaning that the information will have to be reported to the tax authorities by both the supplier or service provider and its counterparty.
The aim is to improve the quality and timeliness of the information available to the tax authorities, strengthen risk analysis and facilitate the detection of potential irregularities and VAT fraud.
The implementation of this system will also make it possible to remove the obligation to submit the annual list of VAT-registered customers for taxpayers covered by the new electronic reporting requirement.
The preliminary draft law must now continue through the legislative process and will be submitted to the Data Protection Authority and the Council of State for their opinions before final approval.
Mandatory B2B e-invoicing in Belgium
The draft law regulating e-invoicing for B2B transactions in Belgium was published on 28 December 2023. Following its approval by the House of Representatives in February 2024 and its subsequent signature by the King, the legislation was officially published.
Since 1 January 2026, structured e-invoicing has been mandatory for both the issuance and receipt of invoices in most domestic B2B transactions between Belgian VAT-registered businesses.
The implementation of B2B e-invoicing provides the foundation for a broader transformation of Belgium's tax compliance model, which is evolving towards greater automation in the exchange and reporting of tax information.
B2G e-invoicing: Background and Current situation
E-invoicing in Belgium has undergone significant developments in recent years, driven by the European Directive 2014/55/EU.
The Flemish region led the implementation in 2016 by adopting e-invoicing in all its public institutions, marking the beginning of a country-wide transition process.
In 2018, this obligation was extended to the federal level for contracts above €135,000, becoming mandatory for all federal authorities in 2019.
Implementation process of B2G e-inovicing in Belgium
In 2020, e-invoicing was gradually implemented in all Belgian federal government entities. On 9 March 2022, e-invoicing became mandatory in Belgium for all public sector entities and their associated bodies, both federal and regional.
Starting from 1 November 2022, companies participating in public contracts outside the European Union are required to use electronic invoicing within six months of the regulation's publication.
Belgian companies involved in public contracts above 30,000 euros will have to adopt e-invoicing within 12 months of the publication of the regulation, with effect from 1 May 2023.
The third phase, originally scheduled for November 2023, has been postponed to March 2024 and will cover the remaining public contracts (below €30,000). It should be noted that contracts under €3,000 may be exempt from this obligation, depending on the policies of each government agency.
How to exchange e-invoices in Belgium?
In order to send electronic invoices to public administrations, taxpayers can use the centralised Mercurius platform, which is connected to the PEPPOL network. The mandatory format is PEPPOL BIS and electronic signatures are not required.
In the B2B environment, PEPPOL is the reference infrastructure for the exchange of structured electronic invoices in Belgium. Connecting through this network facilitates interoperability between businesses and service providers, avoiding the need to establish individual agreements between all participants and providing a common framework for document exchange.
Building on this infrastructure, Belgium is moving towards a model that will also incorporate near-real-time electronic reporting of certain invoicing data, strengthening the connection between e-invoicing and digital tax control.
This planned evolution will enable the tax authorities to access transactional information more quickly and will replace, for taxpayers subject to the future reporting obligation, the submission of the annual list of VAT-registered customers.
