| Date | Who is affected | What applies |
|---|---|---|
| April 2019 | Public contracting authorities | Obligation to receive e-invoices |
| 1 March 2024 | Suppliers under public contracts of 3,000 euros or more | Obligation to issue e-invoices for contracts published from this date |
| 1 January 2026 | VAT-registered businesses established in Belgium | Obligation to receive and send e-invoices in B2B |
| 1 April 2026 | All businesses in scope | End of the tolerance period, fines apply |
| 1 January 2028 | Suppliers and customers in B2B | Planned e-reporting, law not yet adopted |
| 1 July 2030 | Cross-border B2B transactions within the EU | Mandatory e-invoicing under the ViDA reporting requirements |
Since 1 January 2026, all VAT-registered businesses established in Belgium must be able to receive structured e-invoices. The only exceptions are businesses that carry out exclusively transactions exempt under Article 44 of the VAT Code, and non-established businesses (European Commission).
The obligation to send has applied to businesses of all sizes since January 2026. Businesses in bankruptcy, businesses carrying out exclusively exempt transactions under Article 44, and businesses under the flat-rate scheme pursuant to Article 56 are not required to issue e-invoices. The flat-rate scheme will end no later than 1 January 2028. The small business exemption scheme is not among the exceptions. Transactions with private individuals are outside the scope of the mandate. Businesses with a Belgian VAT number but without a registered office or fixed establishment in Belgium are not subject to the obligation to send. The tax authority has applied this restriction since 1 January 2026 (FPS Finance).
Structured invoices compliant with EN 16931 are mandatory. The default format is Peppol BIS Billing 3.0 based on UBL, as set out in the Royal Decree of 8 July 2025 (Belgian Official Gazette).
Peppol is the default channel. Other channels and EN 16931 compliant formats are only permitted if both parties agree. The tax authority recommends a written agreement for this purpose. Both businesses must nevertheless remain technically capable of sending and receiving e-invoices via Peppol. The government’s transitional platform Hermes was shut down at the end of 2025. If a recipient is temporarily unable to receive e-invoices for technical reasons, the supplier may issue the invoice in another form, such as a PDF. The recipient must restore its ability to receive without delay.
The Royal Decree of 8 July 2025 provides for fines from 1 January 2026 of 1,500 euros for the first infringement, 3,000 euros for the second and 5,000 euros for each further infringement where a business lacks the technical means to issue or receive e-invoices. A further infringement only counts if it is established at least three months after the previous one. Existing fines for missing or incorrect invoices continue to apply. Without a structured invoice, the customer may lose its right to deduct input VAT. The tolerance period from January to March 2026 and the extended tolerance for self-billed invoices until 30 June 2026 have ended.
Under Article 60 of the VAT Code, invoices must be retained for ten years, starting from 1 January of the following year. This period applies to tax that became due on or after 1 January 2023; previously it was seven years. Retention must ensure the authenticity of origin and the integrity of content. For e-invoices, this applies to the structured file in its original form.
Since April 2019, the federal state, the regions, the communities and local authorities have been required to receive and process e-invoices (FPS BOSA). A public contracting authority is therefore always able to receive e-invoices. The only question is whether the obligation to issue applies.
The obligation to issue was phased in by contract value. It applies to contracts published from 1 November 2022 above the European publication threshold, to contracts published from 1 May 2023 with a value of 30,000 euros or more, and since 1 March 2024 to all other contracts. The only remaining exception covers contracts with an estimated value of up to 3,000 euros excluding VAT (Royal Decree of 9 March 2022). Contracting authorities can set stricter rules in their procurement documents. Federal contracting authorities have required e-invoices below 3,000 euros as well since 1 March 2024.
As in B2B, invoices to public contracting authorities must use the Peppol BIS Billing 3.0 format.
Like businesses, public contracting authorities are reachable in the Peppol network via their enterprise number under identifier scheme 0208. Whether a customer falls under the B2G mandate can be checked in the Crossroads Bank for Enterprises (KBO/BCE). Its status as a public contracting authority is listed among the entity’s characteristics.
Mercurius is the central platform for e-invoices to public contracting authorities and is fully built around the Peppol network. It serves as a shared mailroom for the administration and offers a web portal for manual submission and status tracking (European Commission).
Suppliers send their invoices via the Peppol network, and Mercurius forwards them to the responsible body. For an integration from within software, this is the same route as in B2B.
Belgium is a mandatory market with Peppol as the default channel. For Belgian customers, your software must create, send, receive and process e-invoices and credit notes in the Peppol BIS Billing 3.0 format. Receiving is just as important as sending, because every business in scope must be able to receive.
Each end customer needs its own registration in the Peppol network under its ten-digit enterprise number. The last two digits of the Belgian enterprise number are a check digit (modulo 97). Validating the format at data entry can prevent later rejections.
On e-invoices, VAT may only be rounded on the total per VAT rate. Rounding per line is not permitted (peppolcheck.be). If your software rounds per line and then totals, cent differences can occur that lead to rejection. Self-billing has its own specification, Peppol BIS Self-Billing, which requires the supplier to have registered the corresponding document type for receipt.
Agreements on alternative formats or channels apply per trading partner and therefore belong in the master data. For recipients who are temporarily unreachable, your product needs a documented PDF fallback. The retention period is ten years and should be configurable rather than hard-coded.
Under the planned e-reporting, customers will also report invoice data. Incoming invoices should therefore be captured promptly after receipt; batch processing at month end may be too late for this.
To connect to the Peppol network, you can build your own Peppol Access Point or integrate a certified Access Point such as InvoiceRails. A Peppol ID lookup lets you check in advance whether a Belgian recipient is reachable and which formats it supports.
Peppol BIS Billing 3.0 is the OpenPeppol specification for invoices and credit notes in the Peppol network. It is a core invoice usage specification (CIUS) of the European standard EN 16931.
When an e-invoice from your software is rejected, your team has to work out from the validation report which field triggered the message and who can correct it.
From 1 January 2027, companies with more than €800,000 in total turnover in the previous year must send e-invoices.
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