Belgium e-invoicing mandate 2026: Peppol explained

What is Belgium's e-invoicing mandate?

Since 1 January 2026, Belgian VAT-registered businesses must issue and receive structured electronic invoices between themselves, exchanged software to software, in principle over the Peppol network. A PDF sent by email is no longer enough. The mandate matters because it reaches almost every active VAT number, including small businesses under the VAT franchise scheme.

The legal basis is Article 53, paragraph 2bis, of the Belgian VAT Code. Any invoice within scope that is drawn up, issued or sent from 1 January 2026 must be a structured e-invoice, even if the transaction took place in 2025. The structured invoice is the only legally compliant one; a PDF or paper copy may go with it voluntarily, but the customer cannot demand it.

Unlike a clearance model, the Federal Public Service (FPS) Finance does not validate each invoice before it reaches the customer. In 2026 no invoice data is yet sent to the authority: that is the next step, e-reporting, announced for 2028.

Who is in scope, and who is not

The mandate covers transactions between a Belgian VAT-registered supplier and a customer registered for VAT in Belgium. It also applies to businesses under the small-business franchise scheme (annual turnover up to EUR 25,000), as FPS Finance confirmed on 7 April 2026, and to the special agricultural scheme, at least for receiving. A business that only invoices consumers must still be able to receive structured invoices from its Belgian suppliers.

To check whether a customer is VAT-registered, look it up in the Crossroads Bank for Enterprises (BCE/KBO): its status shows VAT-registered since a given date. Invoices to public bodies (B2G) follow a separate regime, compulsory over Peppol for contracts published after 1 March 2024, as a rule from EUR 3,000 excluding VAT.

• No obligation to issue for bankrupt taxable persons
• No obligation to issue or receive for businesses making only transactions exempt under Article 44 of the VAT Code
• No obligation to issue or receive for taxable persons not established in Belgium without a fixed establishment, even if VAT-registered there
• No obligation to issue for flat-rate taxable persons (Article 56), a scheme that ends by 1 January 2028 at the latest
• Invoices to consumers (B2C) are outside the mandate
• Transactions exempt under Article 44 are outside the mandate, whoever issues them

Peppol, Peppol BIS and the EN 16931 standard

Peppol is a decentralised network that FPS Finance compares to a telecoms network. The business's invoicing or accounting software connects to it through a Peppol service provider, and the customer is connected the same way. The default format is Peppol BIS, based on UBL syntax and compliant with the European standard EN 16931; another format that meets the standard is possible only by mutual agreement.

Registering on the Peppol network counts as consent to receive structured invoices, and the Peppol Directory shows which customers, including foreign ones, can be reached. There is no need to ask each customer for a Peppol ID. The authority recommends a Peppol-first approach: if the trading partner is connected, the software sends through Peppol automatically.

Two practical points come up often in the official FAQ. Attachments are legally part of the invoice and must travel inside the same UBL message, never by separate email; the extensions allowed today are pdf, png, jpg, csv, xlsx and ods. And a customer cannot unilaterally require invoices to be uploaded to its own portal without the supplier's written agreement.

The tolerance period and the fallback rule

FPS Finance granted a tolerance period for the first three months of 2026: no penalties for offences specific to the new obligation, provided the business could show it had taken timely and reasonable steps to comply. That general tolerance ended on 31 March 2026, as the authority confirmed on 7 April 2026.

A targeted tolerance stayed in place until 30 June 2026 inclusive for self-billing where the software provider was still building the feature. Beyond that, the authority can still waive a fine in exceptional circumstances, but only after an individual review of the case.

The fallback rule, applied since 1 January 2026, says that if the customer is technically unable to receive a structured invoice, the supplier may issue a paper invoice or a PDF. The supplier then meets its obligation, but the customer remains in breach and must put things right without delay. On the purchasing side, the right to deduct VAT is not refused if the substantive conditions are met, even without a structured invoice.

Fines under the Royal Decree of 8 July 2025

The existing VAT fines for missing or non-compliant invoices also apply to structured e-invoices: a proportional fine when an invoice is not issued or mandatory details are missing or wrong, and a non-proportional fine for a late invoice or for breaching the technical rules on semantics, syntax and transmission in Article 13ter of Royal Decree No. 1.

The Royal Decree of 8 July 2025 added a specific fine where a business lacks the technical means to issue and receive a structured e-invoice. An offence only counts as a second or later one if it is found at least three months after the previous one. A business inspected three times without getting equipped would thus pay 1,500 + 3,000 + 5,000 = EUR 9,500, before any fines on the invoices themselves.

• First offence: EUR 1,500
• Second offence: EUR 3,000
• Further offences: EUR 5,000

Tax incentives: the 120% cost deduction and the 20% digital investment deduction

To offset adaptation costs, two tax measures target the self-employed and SMEs. Since 1 January 2025, the investment deduction for digital investments has been raised to 20 percent. For tax periods 2024 to 2027, small SMEs and the self-employed using subscription formulas can apply an increased cost deduction of 120 percent for invoicing packages and advisory fees incurred for the new obligations.

The increased deduction covers only direct costs that are not capitalised: periodic subscriptions and advice. If an existing subscription goes up to include e-invoicing, only the extra cost qualifies, and it must be shown separately on the software provider's invoice. A small company under Article 1:24 of the Belgian Companies and Associations Code does not exceed more than one of these criteria: turnover of EUR 11,250,000, a balance sheet total of EUR 6,000,000 and 50 employees.

Example: a small SME pays EUR 1,000 excluding VAT a year for its Peppol module. It deducts 1,200 instead of 1,000. At a corporate tax rate of 25 percent, the extra 200 cuts tax by EUR 50; the total tax saving rises from 250 to 300.

Worked example: invoice, credit note and journal entries

A company in Liège delivers equipment worth EUR 2,000 excluding VAT to a VAT-registered customer in Ghent, at 21 percent. VAT is 420 and the Peppol invoice totals 2,420, with VAT category S on the lines. The entry under the Belgian minimum chart of accounts (PCMN): Dr 400 Trade receivables 2,420 / Cr 700 Sales and services 2,000 / Cr 451 VAT payable 420.

The customer then returns equipment worth 500 excluding VAT. The fix is never to edit the invoice already sent: the supplier issues a Peppol credit note for 500 plus 105 VAT, 605 in total, which travels over the same network. Entry: Dr 700 500 / Dr 451 105 / Cr 400 605. The customer balance falls from 2,420 to 1,815, which is 1,500 plus 21 percent.

E-reporting planned for 2028 and what an ERP must prepare

According to the FPS Finance FAQ, e-reporting, meaning near real-time transmission of invoice data to the authority, is in the federal coalition agreement with a 2028 horizon but still has to be written into Belgian law. It will replace the annual customer listing and can be automated from the structured invoice. For intra-EU transactions, the ViDA package requires similar reporting, which Belgium will implement by 1 July 2030 at the latest.

In other words, the invoice data travelling between businesses today is the data the authority will receive tomorrow. An ERP that produces clean Peppol invoices in 2026 is already preparing for e-reporting.

Receiving deserves the same attention as sending. An incoming Peppol invoice arrives as data: supplier, lines, VAT rates and amounts. That is a chance to remove rekeying from accounts payable, but an invoice with no purchase order, from an unknown supplier or with quantities that differ from what was received must land in an exception queue with a named owner rather than sit unprocessed. An invoice received and never recorded becomes an unrecorded liability, which the auditor will find at year end if nobody finds it sooner.

• Company number and VAT number of customers and suppliers, checked against the BCE/KBO
• Rates of 21, 12 and 6 percent and the right VAT category on every line
• The detailed reverse-charge mention where it applies
• Continuous numbering and corrections by credit note only
• Attachments embedded in the UBL message
• Item descriptions available in the language the document requires: French, Dutch or German
• Matching of received invoices against orders and goods received

Peppol invoicing with Skyline Nexus ERP

Skyline Nexus ERP already holds the core invoicing data a Peppol invoice is built from. Each business location chooses its own numbering scheme, VAT rates and tax groups are set in Settings > Tax Rates, and with auto-post on, a final sale posts a debit to receivables and credits to revenue and VAT payable, with VAT computed line by line in the same way as the tax report. Sales returns produce credit notes that reverse revenue, VAT and cost of sales, and the VAT return is prefilled per period and location, while VAT Analysis reads the VAT accounts in the general ledger.

National e-invoicing connectors are being rolled out market by market: tell us you operate in Belgium and we will confirm your Peppol go-live date. Until then, the working route is a partner-led integration with a Peppol service provider: the Connector module's REST API exposes sales, returns, contacts, taxes and payments, and supplier invoices received over Peppol can be brought in from the provider's spreadsheet export with Import Purchase, which offers a preview and can revert a batch.

The team knows regulated exchanges: Skyline Nexus ERP runs Saudi Arabia's ZATCA Phase 2 integration in production, with certificates, compliance checks, invoice clearance and reporting, XML and QR codes. The interface is available in English and Arabic, with interface translations including French and Dutch.