Legislation mandating B2B e-invoicing 1 January 2026 now gazetted
Belgium is still waiting on permission from the European Commission to impose mandatory e-invoicing, and derogate from the EU VAT Directive (articles 218 and 232). It applied in October 2023.
Peppol-based e-invoicing for resident taxpayers
The new regime will be limited to Belgian-resident companies, local subsidiaries of foreign companies and non-resident businesses with a VAT registration and Fixed Establishment (premises, staff etc.). However, an important update in this latest Bill is that potentially non-resident customers will have to accept e-invoices from their resident Belgian suppliers for domestic supplies.
It will be based on Peppol 4-corner model (so no direct govt reporting initially) – although other exchange platforms may be used by mutual agreement provided it is compliant with EU requirements. In the mid-term, an e-reporting regime will be introduced for B2C transaction reporting.
Belgium is long-term aiming for a 5-corner Peppol-model. As well as e-invoicing, this will include near-live e-reporting to replace the annual customer listing report. The aim is to help reduce the VAT Gap, the difference between forecast and actually collected tax. The latest Belgian VAT Gap is estimated by the EU to be €4.8bn per annum.
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Belgium’s preferred plan is two staged: PEPPOL-based structured e-invoicing between taxpayers – 4-corner; then enhanced with Continuous Transaction Control pre-clearance with the tax authorities – 5-corner. Belgium is looking to synchronise with the EU VAT in the Digital Age plans for an EU standard on eInvoicing (EN 16931) system across the EU to ensure interpretability. Under the Digital Reporting Requirement pillar, there is a planned mandatory structured e-invoicing requirement in the EU for intra-community supplies from 2030 or later.
Currently, B2B e-invoicing is permitted without the requirement to produce a paper-invoice provided both partiers confirm their agreement and there are sufficient secure controls over the issuance, receipt and storage processes.