Disclaimer: These questions are intended for software developers and tax experts and not for end users (companies, particularly SMEs and sole traders).
- What happens if the customer only accepts the new format while the transition period is still underway (for example, when a new version of Peppol-BIS is released)?
- How can my company become a Peppol service provider?
- What about the specific requirements of public authorities (eg. third-party payment system)?
- Are duplicate invoices a problem for Peppol?
- Are credit notes also sent via Peppol?
- Are annexes to invoices also sent in XML format via Peppol?
- Can different Tax Category Codes appear on the same invoice?
- Can the Tax Category Code “0” be combined with other Codes (like “E” or "S") on a same invoice?
- The list of exemption codes (VATEX) is not full. Which code should I use if an exemption is not included in the list?
- Can different “grounds for exemption” be mentioned for several lines of a same invoice with the Tax Category Code “E”?
- Can extended VAT clauses (e.g. reverse charge mechanism), which must be mentioned on the invoice in accordance with Belgian VAT legislation, also be included on a Peppol invoice?
- What happens when different orders have to be included on a single Peppol invoice?
- Is it possible to use different currencies on an invoice?
- In which field should the data for the register of legal entities (RPM), legal form and “in liquidation” be entered?
- How can I declare part of the costs mentioned on private invoices as business expenses? When can I exercise my right to deduct the VAT shown on my incoming invoices?
- Can I still send summary invoices?
- Can the date of the taxable event by supply of goods or services be included?
- Can I still send simplified invoices (art. 13 RD1)?
- Can I draw up an invoice in several languages?
- What is an extension?
- Where do I mention the buyer's (authorised) tax representative?
- How does self-billing through Peppol work?
- Should a 2026 credit note relating to a 2025 invoice be issued as a structured electronic invoice (SEI)?
- As a customer, do I risk losing my right to deduction if I do not have a structured electronic invoice (SEI)?
- What about authorised representatives?
- What sanctions can be imposed for non-compliance ?
- The invoice does not include the mandatory detailed information required in the event of reverse charge (RD No. 1, Article 20, § 3). Should I reject the invoice or ask for it to be corrected?
- I have received an invoice that is not intended for me (no goods or services have been provided; for example, the sender has misidentified the recipient). What should I do?
- When sending the invoice, I have misidentified the recipient. What should I do if I notice that an outgoing invoice has been sent to the wrong recipient?
- Does the new e-invoicing requirement also apply to transactions referred to in Articles 12 and 19 of the VAT Code (disposals and first occupations)?
- Which Tax Category Code should be used for special VAT schemes (margin scheme, recovered products, etc.)?
- What is the minimum information that must be included for an invoice to comply with Belgian law?
Certified service providers know that there is always a transition period that must be respected. If you believe that you have discovered such an violation, please inform the Belgian Peppol authority by sending an e-mail to peppol@bosa.fgov.be.
2. How can my company become a Peppol service provider?
This question is addressed on the website of our national Peppol authority, FPS BOSA: peppol.be.
3. What about the specific requirements of public authorities (eg. third-party payment system)?
If the invoice is also to be sent to a third party, this must be done manually. In the future, it should be possible to automate this via Peppol. This is further explained on the website of the FPS BOSA.
4. Are duplicate invoices a problem for Peppol?
Peppol doesn't know whether an invoice is a duplicate of the original invoice or not. From a tax point of view, the most important aspect is that the same invoice cannot be accounted for and declared twice. In a digital world, duplicate detection can be automated on the basis of invoice information (number, date, content, identity of parties). Ideally, duplicate detection should be included in the accounting system.
5. Are credit notes also sent via Peppol?
Yes, they are. Any document that modifies the original structured electronic invoice and refers to it specifically and unambiguously is considered to be a structured electronic invoice and is issued in the same format as the original invoice. Credit and debit notes must therefore also be sent via Peppol.
6. Are annexes to invoices also sent in XML format via Peppol?
The European Standard (which Peppol follows) currently authorises the following file extensions pdf, png, jpg, csv, xlsx, ods. The XML format is not yet included in this list but will be added in the revised version of EN16931. If the parties agree, the XML format can now be used as a file extension.
7. Can different Tax Category Codes appear on the same invoice?
Yes, Peppol authorises several codes on a same invoice.
8. Can the Tax Category Code “0” be combined with other Codes (like “E” or "S") on a same invoice?
For the moment, the European Standard (which Peppol applies) does not allow the combination of “O” (outside the scope of VAT) and “E” (exempt transaction) or "S" (standard tariff). The European Standard requires separate invoices to be issued for this purpose. However, as this will change with the revision of the European Standard (EN16931), it is temporarily and exceptionally permitted to use the category “E” for transactions falling outside the scope by indicating in the free text field of the exemption (business term 120: cbc:TaxExemptionReason) that the line does not fall within the scope of application. This applies to all cases where transactions falling outside the scope of VAT in combination with transactions falling within the scope of VAT must be included on the same invoice.
The revision of the VATEX codes and the inclusion in this list of exemptions specific to Belgium are the subject of negotiations at European Union level. In the meantime, you can indicate the applicable exemption in the exemption free text field (business term 120: cbc:TaxExemptionReason).
At present, the European Standard explicitly states that when several goods or services are exempt from VAT (“Exempt”), all the lines of the invoice must fall under the same exemption reason. The European Standard requires separate invoices to be issued for this purpose. However, as this will change with the revision of the European Standard (EN16931), it is temporarily and exceptionally permitted to to mention the different reasons for exemption on the line of the invoice in business term 127:cbc:Note. In the free text field for the exemption (business term 120: cbc:TaxExemptionReason), you can restrict yourself to “Exempt from VAT”.
These extended VAT clauses must be included as a note on the Peppol invoice:
- a general note on the invoice (business term 22: cbc:Note)
- a note at line level (business term 120: cbc:TaxExemptionReason)
12. What happens when different orders have to be included on a single Peppol invoice?
The European Standard does not currently allow this. The European Standard requires separate invoices to be issued for each order. This will change when EN16931 will be revised (scheduled for 2025). The Business Expert Group (BEG) has worked out a temporary solution allowing multiple orders to be listed on one Peppol invoice.
13. Is it possible to use different currencies on an invoice?
Yes, but the total amount of VAT must be stated in the national currency (see Article 5, §1, 9°, of royal decree no. 1). The “Business Expert Group on E-invoicing” (BEG) illustrated this scenario with a number of examples. You can find more information on this subject on the BEG page.
These data, required by the Companies and Associations Code (article 2:20 CSA), can preferably be included in business term 33: cbc:CompanyLegalForm.
You wish to declare as business expenses some of the costs mentioned on private (B2C) invoices that you receive (e.g. for gas, electricity, water, etc.)? You can do this on the basis of the invoices you receive, regardless of whether they are in paper or electronic format. These invoices are not covered by the new obligation to send and receive structured electronic invoices.
In order to exercise the right to deduct the VAT mentioned on your incoming invoices, you must have a regular B2B invoice (see article 3, §1, 1°, of royal decree no. 3 of 10.12.1969).
16. Can I still send summary invoices?
Yes, it is still possible to send summary invoices.
17. Can the date of the taxable event by supply of goods or services be included?
If this date differs from the date of issue of the invoice, the date of the taxable event must be included at invoice level (business term 72: cbc:ActualDeliveryDate) or at line level (business terms 134+135: cbc:StartDate and cbc:EndDate). The revision of the European standard (EN16931) will allow a separate 'ActualDeliveryDate' to be added at line level.
18. Can I still send simplified invoices (art. 13 RD1)?
Yes. This should also be (at least) via the Peppol-BIS format.
19. Can I draw up an invoice in several languages?
EN16931 does not allow, for example, the name of the product (BT-153: cac:Item/cbc:Name) to be mentioned in two languages (by using the attribute 'languageID'). Since multilingualism applies to all mandatory information on an invoice, this also adds complexity for all parties involved. No agreement has been reached on including this in the core invoice of the European standard, but the topic is part of discussions on the use of extensions.
Companies can agree on the use of extensions (extended specifications of the European standard) to support specific business requirements that are not part of the core invoice of the European standard. In order to avoid each Member State and sector developing their own extension, negotiations are ongoing at European level with a view to achieving as much harmonisation as much as possible at EU level.
21. Where do I mention the buyer's (authorised) tax representative?
There is no separate field in the European standard for the details of the customer's tax representative. You can include the details of the individual or global authorised representative via business term 22: cbc:Note.
22. How does self-billing through Peppol work?
Peppol provides a separate document type (self-billing invoice/self-billing credit note) that the recipient needs to log into Peppol. Unlike a standard invoice (where the customer registers as the recipient), with self-billing it is the supplier or service provider who must register in order to receive the self-billing invoice or self-billing credit note. Please note: A prior agreement is still required, as is acceptance of each self-billing invoice or self-billing credit note.
Any document that:
- makes changes to, and
- specifically and unambiguously refers to
the structured electronic invoice (SEI) originally issued, also qualifies as a SEI. This applies in particular to credit notes. Such document must be issued in the same format as the original invoice. This requirement therefore only applies if the original invoice is a SEI. If this is not the case (e.g. an original invoice in PDF format), there is no format requirement.
In 2026, it must still be possible to issue a credit note as a PDF, as long as the customer accepts this (Art. 56, § 2 (4) of the VAT Code). If the supplier decides to issue the credit note as a SEI, which in theory, is mandatory as from 1 January 2026, the customer has to accept it, as this is not a voluntary issue of a SEI.
In order to exercise the right to deduct the VAT mentioned on your incoming invoices, you must have a regular B2B invoice (Art. 3, § 1, 1°, of RD No 3). For a transaction covered by the obligation, you must therefore have a structured electronic invoice in order to exercise your right to deduction. There is an exception, bound by specific conditions: the so-called substance over form (VAT Commentary, Bookwork III: Right to deduction of the input tax, Chapter 11: Right to deduction, Section 14 - Exercise of the right to deduction, 2(b) and (c)). If the material conditions are met, the right to deduction will not be denied. However, you may be liable to an administrative fine if you do not have the technical means required to receive a structured electronic invoice.
25. What about authorised representatives?
The Belgian company representing a taxable person not established in Belgium without a permanent establishment in Belgium, for VAT purposes in Belgium, is subject to the new SEI obligation under its own Belgian VAT identification number.
This does not apply when that Belgian taxable person acts:
- as an individually liable representative (and uses the BE VAT identification number allocated to the taxable person not established in Belgium), or
- as a globally liable representative (and uses the specific VAT identification number allocated for this purpose with initials BE0796.5 or BE0796.6).
26. What sanctions can be imposed for non-compliance ?
The existing tax fines for failure to issue invoices and for issuing non-compliant invoices remain in place and also apply to structured electronic invoices:
- When a structured electronic invoice has not been issued, is missing mandatory information or contains inaccuracies: proportional tax fine in accordance with the provision of Table C of the Annex to Royal Decree No 41 of 30 January 1987.
- When an electronic invoice has not been drawn up or issued within the deadline: non-proportional tax fine in accordance with the provision of point A of heading I of section 2 of the Annex to Royal Decree No 44 of 9 July 2012.
- When a structured electronic invoice does not comply with other legal obligations (excluding obligations included in another section): non-proportional tax fine in accordance with the provision under B of heading I of section 2 of the Annex to Royal Decree No 44 of 9 July 2012
For a structured electronic invoice, that description will include, in particular, offences resulting from failure to comply with the specific technical modalities to be observed when issuing structured electronic invoices in accordance with Article 13ter, new, of Royal Decree No. 1 (semantics, syntax and transmission requirements).
The 2018 penalty policy continues to apply.
A new sanction was introduced in the Royal Decree of 8 July 2025. Thus, pursuant to Article 5 of the Royal Decree of 08 July 2025, heading I of section 2 of the Annex to Royal Decree No. 44 of 9 July 2012 laying down the amount of non-proportional tax fines in the field of value-added tax is supplemented by the provision under C, which reads:
'C. Failure to have the technical means to issue and receive a structured electronic invoice
- first offence: 1,500 euro
- second offence (1): 3,000 euro
- following offences (1): 5,000 euro
(1) For the purposes of the first paragraph, an infringement may only be considered a second or subsequent infringement if it has been established by the administration no earlier than three months after the previous infringement that gave rise to an administrative fine, has been established by the administration.
No, provided that the invoice does state ‘reverse-charging of VAT’ or ‘reverse charge’. The mandatory detailed information required under Article 20, § 3 of RD No 1 may be included in a field for additional, unstructured information. If this mandatory detailed information is missing, it is primarily the service provider who is affected. In that case, the clause transferring liability for the correct application of the reverse-charge system to the customer cannot take effect. You should not reject the invoice, but you can obviously contact your service provider to point out that this information is missing. On the basis of this document, the recipient can still reverse-charge the VAT, in accordance with Article 20 of RD No. 1.
If you have received an invoice that is not intended for you, it obviously does not qualify for tax deduction (see, for example, point 25 Case C-712/17). According to an opinion from the Accounting Standards Commission, that invoice should not be included in the accounts either.
You should reject the invoice. If you wish, you can contact the supplier or service provider to inform them of their mistake. This situation has not changed with the introduction of e-invoicing. You can reject the invoice via Peppol by sending an Invoice Response (IR) with status code ‘RE’ (Rejected), as specified in Peppol BIS Invoice Response. If the functionality for electronic refusal is not yet available, please contact your software supplier.
If you send an invoice to the wrong recipient:
- If VAT is chargeable,
- that invoice must be registered in the book of outgoing invoices, and
- the amounts must be included in the periodic tax return (Art. 51, § 1, 3° of the VAT Code, Art. 53, § 1, first paragraph, 2° of the VAT Code, Art. 14,§ 2 RD1).
The amounts wrongly invoiced must be included in a corrective document (Art. 12, § 1, RD1) (in practice: a credit note).
This situation has not changed with the introduction of e-invoicing.
No, it does not. For these transactions, there was and is no invoicing requirement.
Consequently, there can be no obligation to issue structured electronic invoices. However, the special document referred to in Article 3 of RD No. 1 must be drawn up for those transactions.
The ‘Business Expert Group on E-invoicing’ (BEG) has elaborated on this scenario with examples. Further information can be found on the BEG website.
32. What is the minimum information that must be included for an invoice to comply with Belgian law?
The ‘Business Expert Group on E-invoicing’ (BEG) has elaborated on this scenario with examples. Further information can be found on the BEG website.