Target
Introducing compulsory e-invoicing between Belgian enterprises liable to tax as from 1er January 2026 is an important step in the digitalisation of our economy. In the meantime, more than half a million enterprises, large and small, have already taken the plunge. Many enterprises are now entering the final stage of preparation. Since September, we are seeing a quick acceleration week after week in the adoption of this system, with a peak expected just before the deadline. Besides, the transition to e-invoicing will be relatively straightforward for many enterprises.
Tolerance
However, we understand that during the implementation of e-invoicing, as with any major operational innovation, certain practical problems may arise or that enterprises liable to tax acting in good faith may not yet be able, for reasons beyond their control, to fulfil all their obligations correctly.
For this reason, the FPS Finance will show tolerance during the first three months of 2026 and will not apply penalties for any offence relating to the new obligation of e-invoicing. This tolerance is granted provided that the enterprise can demonstrate that it has taken steps in a timely and reasonable manner in order to comply with the new obligation.
What offences are covered?
The offences must be specific to the new obligation:
- The enterprise does not (yet) have the technical means to send and/or receive a structured electronic invoice (in full or for certain transactions, e.g. delivery by the contracting partner [self billing]).
- The enterprise does not issue a structured electronic invoice even though this is mandatory, because their own system or that of a third party they use does not yet allow a valid electronic invoice to be issued (in full or for certain transactions, for example delivery by the contracting partner [self billing]).
It goes without saying that, in these cases, the enterprise issuing the invoice must fulfil their invoicing obligations in another way (alternative format or sending method).
Why the condition “in a timely and reasonable manner”?
Enterprises who have already made sufficient efforts to ensure that e-invoicing is applied in a timely and correct manner will have the opportunity to comply with all obligations in this matter without enduring any penalty.
Enterprises who have not done so will be encouraged to comply with all obligations as soon as possible.
Any penalty will depend on the specific circumstances of the case. Each case will be assessed individually.
Under no circumstances will we grant a general postponement. This would be unfair to all the enterprises that have tried to be ready in a timely manner, to all the people who support them as well as to all the IT companies that have invested in order to meet the deadline of 1st January 2026.
It would also mean that the benefits of e-invoicing would be delayed. There is also the additional risk that some people among the those targeted, with no obligation of means, will not meet the new deadline either, which would simply shift the problem over time.
Invoicing requires reciprocity: the better prepared all counterparts are, the smoother the transition will be.
Questions?
Consult the FAQ on our website einvoicing.belgium.be.
