- Has Belgium received Europe's authorisation to introduce the obligation?
- Is e-invoicing compulsory in Belgium? For which B2B transactions does the obligation not apply? Is e-invoicing also compulsory if I only work for private individuals? When will e-invoicing become compulsory? How do you know if a company is liable for VAT? Is e-invoicing also mandatory if I apply the Small Enterprises exemption scheme? Is e-invoicing also mandatory for farmers under the special agricultural scheme? Is e-invoicing also mandatory for persons liable to VAT not established in Belgium without a permanent establishment?
- How can I prepare my company for e-invoicing?
- What software do I need for e-invoicing?
- Are there any costs associated with using e-invoices? Are there any tax incentives for adopting e-invoicing?
- Can I also use e-invoicing outside Belgium, international?
- What should I do if my supplier is not ready on 1 January 2026?
- What should I do if my customer is not ready to receive invoices via Peppol on 1 January 2026?
- Can I use structured e-invoices if they are not compulsory?
- Is self-billing authorised?
- Can electronic and paper invoices coexist?
- Is it mandatory to send the invoice as a PDF attachment?
- The list of solutions is rather extensive. Can the government themselves offer a free solution for small businesses? Can you add the type of software to the list? Can you add the price to the list? Can the government reduce the list to a more limited number of choices for small businesses?
- When does e-invoicing become mandatory?
- Should I ask my customers for a Peppol ID?
- Is a structured electronic invoice sufficient on its own, without the issuance of a receipt from a registred cash register system?
- Should the PDF invoice attached by the sender or created by the recipient be kept?
- Can I be obliged to submit my invoices through a customer portal?
- Can I submit attachments through another channel (e.g. e-mail)?
- Why must attachments be sent through the same channel?
- Can I send attachments within the Universal Business Language (UBL)?
- What happens if I do send attachments separately?
- The software I am using does not yet allow for the sending or receipt of self-billing invoices (invoicing by the contracting partner) and does not yet process them automatically. Am I at risk of sanctions?
1. Has Belgium received Europe's authorisation to introduce the obligation?
On 6 October 2023, Belgium submitted a request to the European Commission, under Article 395 of the Directive 2006/112/EC, for authorisation from the Council to derogate from the VAT Directive. In the meantime, there is agreement at European level on the so-called ViDA (VAT in the Digital Age) proposal, which was approved in its final version at European level on 11 March 2025, following the political agreement on the text on 5 November 2024.
As a result, Member States no longer need authorisation to introduce an e-invoicing obligation (this applies with immediate effect).
These questions are addressed in the following article: For whom will e-invoicing become compulsory? - e-invoicing.
The obligation applies if you make use of the exemption scheme for small businesses (if your company's annual turnover does not exceed €25,000) and also if you fall under the special agricultural scheme (at least for receiving B2B invoices).
VAT-registered persons not established in Belgium without a permanent establishment, even if they are identified for VAT purposes in Belgium, are not subject to the obligation. The law is still being amended on this point.
3. How can I prepare my company for e-invoicing?
Businesses need to assess their current invoicing and accounting systems and, if necessary, adapt them so that they can send and receive structured e-invoices. It is advisable to contact your software supplier to check whether your current systems are compatible with e-invoicing via the Peppol network.
For a more detailed answer to this question, you can consult the following articles (depending on your situation):
- An external accountant draws up my invoices. How do you prepare for electronic invoicing?- e-invoicing
- I draw up my invoices in Word/Excel/pdf/paper. How to prepare for einvoicing ?- e-invoicing
- I use an ERP system. How to prepare for e-invoicing?- e-invoicing
- I use external invoicing software. How to prepare for e-invoicing?- e-invoicing
General article: What do I need for e-invoicing?- e-invoicing
4. What software do I need for e-invoicing?
You need a software connected to the Peppol network to send, receive and process e-invoices.
For more information, please consult the following article: Software solutions for sending, receiving and processing electronic invoices - e-invoicing.
These questions are addressed in the following article: Tax incentives for adopting e-invoicing - e-invoicing.
6. Can I also use e-invoicing outside Belgium, international?
This question is addressed in the following article: Can I also use electronic invoicing outside Belgium, international?- e-invoicing.
7. What should I do if my supplier is not ready on 1 January 2026?
If your supplier is not ready, you have theoretically the right to refuse the invoice. However, this is not always obvious from a commercial point of view. Ask your supplier if they are going to comply. The supplier risks to be penalised. In this case, the customer retains the right to VAT deduction based on the invoice issued in an alternative form (e.g. in PDF or paper form). If the invoice is issued electronically, the customer must agree to this. There must be agreement on a secure alternative.
8. What should I do if my customer is not ready to receive invoices via Peppol on 1 January 2026?
If your customer is not ready to receive invoices through Peppol, you, as sender, can choose another transfer method. If the invoice is issued electronically, the customer must agree to this. There must be agreement on a secure alternative. On a voluntary basis, you can add a clause to the invoice to encourage the recipient to comply. The customer risks to be penalised. The invoice sent by alternative means is legally valid and the sender thus fulfils their legal invoicing obligation. Once the customer's system is operational, suppliers should not send structured electronic invoices retroactively.
9. Can I use structured e-invoices if they are not compulsory?
Anyone is free to use structured e-invoices on a voluntary basis, even in situations where they are not legally required. As there is no obligation for this transaction, your client is thus not required to be able to receive a structured e-invoice for this operation. This will only be possible when both parties agree to work in this way and the customer agrees to receive structured e-invoices.
Note that the Peppol network provides for the publication of registered invoice recipients and that the rules of this network imply that this publication constitutes agreement to receive structured e-invoices. Most invoicing tools use this information to dynamically "detect" these new recipients. Via the Peppol Directory you can also check by yourself (see also the questions “What is a Peppol ID?” and “As an entrepreneur, can I check which customers and suppliers are connected to Peppol?”, which customers (even international clients) are ready and willing to receive structured e-invoices in a secured way.
10. Is self-billing authorised?
The rules on this subject remain unchanged. Self-billing remains authorised provided that :
- there is a prior agreement between both parties, and
- each invoice is subject to an acceptance procedure by the taxable person making the supply of goods or services.
Self-billing is possible via Peppol.
11. Can electronic and paper invoices coexist?
Until 31 December 2025, you can use both e-invoices (with the consent of the recipient) and paper invoices. As from 1 January 2026, the structured e-invoicing will be compulsory for transactions between Belgian enterprises liable to VAT (B2B). If you wish, you can also voluntarily send a PDF or paper version of the invoice to your client, but the structured electronic invoice is the only legally required invoice.
12. Is it mandatory to send the invoice as a PDF attachment?
No, it is not. The recipient cannot reject the invoice because the invoice has not been attached as a PDF. Therefore, this cannot be made mandatory.
These questions are addressed in the following article: The list of solutions is long, I don't know where to start. Can't the government provide a free solution for small businesses? - e-invoicing.
14. When does e-invoicing become mandatory?
As from 1 January 2026, any invoice falling within the scope of the electronic invoicing obligation that is drawn up, issued or sent as from 1 January 2026 must be in the form of a structured electronic invoice (as referred to in article 53, § 2bis, new, of the VAT Code). It does not matter whether the transactions covered by the invoice were carried out before or after 1 January 2026.
15. Should I ask my customer for a Peppol ID?
No, you should not. This is explained in the item 'What is a Peppol ID?'.
No, it is not. When the customer is a taxable person or a non-taxable legal person, an invoice should always be issued in addition to the receipt from a registered cash register system. The obligation to issue structured electronic invoices from 1 January 2026 does not change this principle.
17. Should the PDF invoice attached by the sender or created by the recipient be kept?
The rules on storage of electronic invoices have not changed. The recipient must therefore keep the structured electronic invoice for the full storage period. In addition, the legibility of an invoice must be guaranteed throughout its storage period. In practical terms, this usually takes place via a PDF or a viewer (a secure environment in which invoices can be accessed in a legible format). This is still necessary for tax audits and will also be required by other parties for whom the submission of an invoice may be procedurally necessary (courts, banks, insurance companies, local authorities, provinces, regions, etc.). If the legible form is a PDF, the integrity of the content must be guaranteed. This means that the prescribed content of the electronic invoice may not be modified.
18. Can I be obliged to submit my invoices through a customer portal?
No, not without your consent. As from 1 January 2026, structured electronic invoices should in theory be exchanged via the Peppol network. A customer cannot unilaterally impose that you submit an invoice exclusively through its own portal, unless you explicitly agree to this. This prevents suppliers from facing additional costs or complex processes. Avoid implicit agreements: without clear written consent, a customer cannot oblige you to do so.
19. Can I submit attachments through another channel (e.g. e-mail)?
No, you cannot. All attachments related to an invoice should be sent through the same channel. It is not allowed to submit attachments through a separate channel (such as e-mail). The European Standard (followed by Peppol) currently allows the following file extensions: pdf, png, jpg, csv, xlsx, ods. Xml is not yet part of this list, but will be included in the revised version of EN16931. If the parties mutually agree, xml can already be used as a file extension today.
20. Why must attachments be sent through the same channel?
Because attachments that supplement the invoice are legally part of the invoice itself. Therefore, they must be transferred along with the invoice.
21. Can I send attachments within the Universal Business Language (UBL)?
Yes, you can. The UBL invoice allows attachments to be directly included. This is the correct and legally required way to deliver additional documents. It can be done either by including them in the UBL invoice itself or via an external link (e.g. when the attachment is too large).
22. What happens if I do send attachments separately?
Attachments sent through another channel:
- will cause delays in processing,
- create a risk of mismatches or incomplete files, and
- are in conflict with the law, as attachments that supplement the invoice form an integral part of that invoice.
Where the sending or receipt of structured electronic self-billing invoices is not yet technically possible on the part of the issuer or the recipient, the administration will exercise flexibility till 30 June 2026, provided that the company concerned can demonstrate that its software provider is still in the process of implementing the necessary functionalities. In such cases, self-billing invoices may temporarily be issued and transmitted by other means, without sanctions for either the issuer or the recipient.
Automatic processing does not constitute a legal obligation.