Scope of B2B e-invoicing in Belgium: 3 key criteria
Currently, the scope of the Belgian B2B mandate for e-invoicing is as follows:
- The issuer – or supplier – must be a taxable entity based in Belgium. Certain taxpayers, such as those involved in specific exempt transactions, those under a special flat-rate scheme, or those in bankruptcy, are exempt from this requirement.
- The customer receiving the e-invoice – the buyer – must have a Belgian VAT number or be obligated to register for VAT in Belgium. Customers cannot refuse electronic invoices.
- The transaction must qualify as a taxable event within Belgium, meaning the mandate is limited to domestic B2B transactions.
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A timeline of e-invoicing events for Belgium
Belgium has chosen not to roll out B2B e-invoicing in phases. Instead, all taxpaying businesses, with a few exceptions, will begin using the system simultaneously on January 1, 2026. This widespread adoption is different from other EU Member States, such as France or Spain.
For the moment, no digital reporting is foreseen in the legislation.
| Type of transaction | Structured e-invoicing | Electronic (PDF) | Paper |
|---|---|---|---|
| B2B* | Mandatory from January 2026 via Peppol-network | Not allowed from January 2026 | Not allowed from January 2026 |
| B2G** | Mandatory since March 2024 via Peppol-network*** | Not allowed | Not allowed |
| B2C, international and other | Allowed when approved by receiver (registration on the Peppol network = approve) | Allowed when approved by receiver | Allowed |
*B2B = All tax-paying businesses
**B2G = Transactions of businesses with government entities
***Some exceptions here (invoices < € 3.000 etc)
How to prepare for e-invoicing in Belgium?
With 2026 fast approaching, all taxpaying businesses must complete their transitions by this deadline. To avoid last-minute headaches and stress, start your digital transformations, process adaptations, plans and roadmaps now.
To be ready for e-invoicing in Belgium, you must ensure the following:
1. The e-invoice
Create your invoice in a structured electronic format, adhering to the European EN16931 standard. While the prescribed format is Peppol BIS, compatible XML or UBL formats are also acceptable. This structured format is essential for exchanging documents within the Peppol network, and automatic and electronic processing.
There are several ways to facilitate exchange in the Peppol network:
- Through your ERP or accounting tool
- By using a service provider
- With the help of your internal IT team
2. Access to a network to exchange invoices
Businesses can use the Peppol network and format, the standard for e-invoicing in Belgium. To connect to the Peppol network, an access point is necessary. Billtrust, a registered Peppol Access Point in Belgium, can provide this service.
Alternatively, businesses can choose to use other networks. This option is only viable when both sender and recipient agree.
3. Choosing the right software
Sending and receiving invoices are distinct processes, so evaluate your current software’s capabilities. It should effectively handle invoice presentation and processing while seamlessly integrating updates into your ERP or accounting systems. A built-in Peppol connection makes things even easier.
Consider reviewing your entire financial ecosystem and IT processes for optimal performance. Make sure your master data – including customer info – is up to date for seamless e-invoicing.
Learn all about Peppol in this comprehensive guide from Billtrust
Tax support to aid transition
You may need to purchase or upgrade your software to meet the 2026 mandate requirements. Given the tight timeline and the fact that all tax-paying businesses are affected, the Belgian government will offer the following tax incentives:
- Starting in January 2025, a 20% deduction is allowed for digital investments.
- In the tax periods 2024 to 2027, small SMEs and self-employed using invoicing software through subscription formulas can apply an increased deduction of 120% on related expenses.
New ViDA developments
The November 2024 changes to the European VAT in the Digital Age (ViDA) package will impact Belgium’s approach to e-invoicing. A major component of the ViDA package is removing the requirement for EU approval to enforce e-invoicing on domestic transactions. This change allows Belgium to implement its own e-invoicing mandate for domestic B2B transactions by 2026.
It is important to note that Belgium must comply with the new EU e-invoicing model by 2035. Countries with existing digital real-time transaction reporting systems will undergo a transition phase. Belgium, along with Italy, France, Poland, Germany, and Romania, has until January 1, 2035, to fully adopt the EU’s revised e-invoicing framework.
The ViDA package does not fully harmonize e-invoicing and DRR frameworks for domestic and intra-EU transactions as initially proposed. This means Belgian businesses operating across multiple EU Member States will still need to navigate varied models and invest in diverse IT solutions to meet these obligations.
Billtrust is here to help
The transition to mandatory B2B e-invoicing in Belgium by 2026 is a significant shift that requires careful preparation. While e-invoicing has many benefits for businesses, there are challenges ahead. Billtrust is here to support you on this journey, making you compliant and your order-to-cash process more efficient. Contact us today.
