Jan 2026 B2B Peppol-based e-invoicing supplemented by Jan 2028 near real-time reporting to govt
The new Belgian coalition government on 31 January 2025 confirmed (‘Federal Coalition Agreement 2025-2029’, or “Arizona deal”) it will introduce near real-time B2B domestic transaction reporting (or ‘e-reporting‘) from 1 January 2028 – a 5-corner Peppol-model. Unlike the French 5-corner model 2026 mandate, it seems businesses can choose to appoint e-invoicing service providers for the exchange of invoices OR use adapted software (EPR’s; accounting packages; invoicing systems etc).
This adds to the already scheduled January 2026 mandate for B2B 4-corner e-invoicing between companies. The requirement apply to VAT registered businesses, including non-residents with a VAT Fixed Establishment (‘FE’). However, non-residents without a Belgian FE need only be able to receive Peppol (or other EN16931 standard) structured e-invoices from their Belgian counterparties.
In addition to B2B e-reporting, there is also to be an extension of the Belgian fiscal cash register mandate for the hospitality sector.
2026 4-corner Peppol e-invoicing between businesses; 2028 transaction reporting
The 2026 Belgian mandate is initially based on Peppol 4-corner model (so no direct govt reporting) – although other exchange platforms may be used by mutual agreement provided it is compliant with EU requirements. The supplier and buyer may do this via e-invoicing Service Providers or e-invoice enabled software / billing system. So far, Belgium has not indicated that there will be a formal accreditation system for providers as there is in countries like France.
The Belgian Federal Public Service Finance (FPS) issued on 15 October a list of registered accounting software for e-invoicing which becomes mandatory for resident businesses from 1 January 2026. These enable the required exchange of Peppol-based structured B2B e-invoices between resident businesses.
From January 2028, Belgium is aiming for a 5-corner Peppol-model. As well as e-invoicing, this will include near-live e-reporting of transaction data (based on e-invoices) 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.
Belgium Federal Public Service issues new guidance
The FPS has issued guidance to all taxpayers for the 2026 e-invoicing mandate. Thus will require all B2B transactions to adopt structured e-invoices – although there is no requirements yet for reporting of the invoice to the tax authorities.
The guidance covers:
- Transactions requiring an e-invoice. From 1 January 2026, the structured electronic invoice will be mandatory for almost all transactions between Belgian VAT companies (B2B). The obligation to issue structured electronic invoices does not apply to deliveries of goods or services to individuals for their private use (‘B2C’ or ‘business-to-consumer’).
- Structure e-invoice format, based on EN 16931 format. This enables automatic and electronic processing of it. Which means to be drawn up in the Peppol-BIS format. This is the stricter definition of an electronic invoice in VAT legislation. PDF may not be used after December 2025.
- Technical rules: authenticity of origin, the integrity of the content and the readability
- International invoices If the shipper or recipient is identified in a country outside Belgium, electronic invoicing is only permitted with the agreement of the recipient. The format and method of transfer are determined in bilateral consultation between sender and recipient.
20 February 2024 – The Bill legislating for mandatory B2B e-invoicing in Belgium has been gazetted, meaning it is now fully adopted for 1 January 2026.
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.
Tax deductions on e-invoicing expenditure and investment
- from 1 January 2025, the investment deduction for digital investments will be increased to 20%; and
- for the taxable periods 2024 to 2027, small businesses and independent contractors using subscription plans can apply an increased fee deduction of 120% for billing programs.
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.
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This would be before the Germany e-invoicing launch of January 2027. French e-invoicing is due September 2026. The EU’s mandatory ViDA e-invoicing has been delayed until July 2030.
Peppol-based regime
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.