Belgium Moves to Peppol with Electronic Invoicing
- Belgium mandates Peppol e-invoicing for all domestic B2B transactions from 2026.
- The reform improves VAT compliance, efficiency, and interoperability across EU trade.
- Non-compliance risks fines, rejected invoices, and loss of VAT deductions.
November 03, 2025 | Accounts Payable 4 minutes read
Belgium has introduced a mandatory structured electronic invoicing mandate for B2B transactions.
In essence, Belgium is moving to Peppol to exchange all B2B domestic invoices electronically. All Belgian VAT-registered businesses will have to issue and accept Peppol invoices for domestic B2B transactions already starting January 1, 2026.
The concept of electronic invoicing is not new in Belgium.
Legislation has supported e-invoicing since 2013, and the business-to-government (B2G) mandate has been gradually expanded, covering all government suppliers as of March 2024.
Why is Belgium Doing This?
There are several drivers behind the policy – and gain for everyone:
1. Tax Compliance and Closing the VAT Gap
Electronic invoices help tax authorities better track transactions, reducing fraud, omissions or misreported VAT. Belgium is aligning with EU initiatives (e.g. the VAT in the Digital Age - ViDA) to improve transparency.
2. Interoperability and Harmonization
Using common European standards (EN 16931, PEPPOL-BIS 3.0) makes cross-border trade and public procurement more seamless. It fits into the EU’s push for digital public services and eGovernment.
3. Efficiency and Cost Savings
Structured e-invoices reduce manual handling, errors, and delays. Automation speeds up processing and payment cycles.
What Changes in Practice
Here are what businesses will need to adjust:
Element | Before 1 Jan 2026 | From 1 Jan 2026 |
|---|---|---|
| Formats accepted for B2B invoices | Paper, PDF, optionally electronic upon agreement | Only structured e-invoices that meet EN 16931/PEPPOL BIS standard for in-scope B2B transactions |
| Obligation to accept e-invoice | Recipient could refuse, depending on agreement | Recipient must accept structured e-invoice if they are in-scope party |
| Use of PEPPOL network | Voluntary or only for B2G/contracts already under rule. | PEPPOL-BIS 3.0 becomes standard and path for compliance |
| Non-compliance implications | Potential risk, but rule not yet strict | Invoices not compliant may not be valid for certain legal or VAT deduction purposes and penalties apply. |
There are some exceptions but not many: exemptions include certain sectors (medical, social, education, cultural), businesses under the flat-rate VAT scheme (phasing out by 2028), companies in bankruptcy with an active VAT number, foreign businesses registered for Belgian VAT without a local establishment (pending clarification), and all B2C transactions.
Watch Our Webcast: Ensure E-Invoice Compliance Across Accounts Receivable and Payable | GEP
Opportunities and Challenges
The move to structured e-invoicing via Peppol brings significant opportunities for Belgian businesses.
One of the key advantages is cost savings, as automated, digital invoicing removes the need for manual handling, printing, and mailing. It also leads to faster payment cycles and fewer invoice disputes, thanks to standardized data formats that reduce errors and omissions. Improved VAT compliance is another benefit, as structured invoices help minimize reporting mistakes and audit risks.
Moreover, e-invoicing integrates more easily with modern accounting and ERP systems, supporting broader digital transformation. Peppol also supports other message types than invoices so entire P2P process benefits from electronic transactions.
However, the transition also presents some challenges.
Businesses must ensure that both their suppliers and customers are ready to exchange Peppol-compliant invoices, which may be difficult for smaller firms or those using outdated systems. Internal processes will need to be adapted. There may also be interoperability concerns when dealing with foreign partners or non-standard formats. Finally, failure to meet the required structure can lead to legal and financial risks, particularly if invoices are rejected for VAT deduction or come under scrutiny in audits.
Penalties for Non-Compliance
Belgium’s e-invoicing mandate includes clear penalties for businesses that fail to comply. The first category is technical readiness, which applies when a company is simply not able to issue or receive structured e-invoices — for example, not being connected to the Peppol network or using incompatible systems. In such cases, fines start at €1,500 for a first offence, increase to €3,000 for a second, and reach €5,000 for each subsequent violation. There is a three-month grace period between violations before penalties escalate.
The second category concerns invoice content or procedural errors. These occur when invoices are sent late or contain mistakes such as missing mandatory fields or incorrect rounding. Such errors can result in penalties of several thousand euros per incident, depending on severity, and may also trigger existing VAT-related fines under broader tax law. Finally, there is the risk of losing VAT deduction rights. If an invoice does not meet the required structured format, it may be rejected for input VAT recovery, which can significantly increase costs. Additional proportional penalties may apply based on the amount of VAT involved.
What Makes the Belgian Model Stand Out?
Belgium’s e-invoicing mandate represents more than a compliance obligation — it reflects a mature, well-prepared digital strategy. The requirements are clearly defined, the technology (Peppol) has been proven in practice for over a decade, and the infrastructure is already in place. There is no reinvention of the wheel: service providers are ready, the framework is stable, and businesses have full visibility of what’s coming. No surprises, no last-minute changes — just execution.
Belgium is also looking beyond invoicing. From January 2028, it plans to replace the annual customer listing with real-time reporting, integrating tax authorities directly into the transaction flow. This evolution, often referred to as the 5-corner model, marks a shift toward continuous, automated compliance.
If your business operates in Belgium or trades with Belgian VAT-registered entities, waiting is the biggest risk. Those who delay may face penalties, operational disruption, or increased costs, while early adopters will benefit from streamlined processes and stronger compliance.
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