Key takeaways
- Structured electronic invoicing is mandatory for all B2B transactions between Belgian taxable persons since 1 January 2026, with no gradual entry phase by company size.
- PDF invoices sent by email no longer meet the legal requirements for B2B exchanges between Belgian companies.
- The reference format is UBL 2.1 via the Peppol network (Peppol BIS Billing 3.0 specification), framed by the European standard EN 16931.
- The tolerance period of the first quarter of 2026 is over: the penalties provided by the royal decree of 8 July 2025 have applied since 1 April 2026.
- Companies under the VAT exemption (less than 25,000 euros of turnover) are not exempt from the obligation.
Since 1 January 2026, electronic invoicing in Belgium has crossed a decisive milestone: all Belgian companies liable for VAT must issue and receive structured electronic invoices for their transactions between Belgian taxable persons. The law of 6 February 2024 (NUMAC 2024001635), published in the Moniteur belge on 20 February 2024, introduced this obligation by inserting an article 53, §2bis in the VAT Code. The tolerance period granted in the first quarter of 2026 ended on 1 April 2026: the rules now apply without a safety net. This guide takes stock of what is in force.
Electronic invoicing in Belgium: the legal framework
Article 53, §2bis of the VAT Code requires every taxable person established in Belgium to issue and receive a structured electronic invoice for supplies of goods and services to another VAT taxable person in Belgium. The obligation covers both directions of the exchange: sending structured invoices AND being able to receive them.
The notion is precise. A structured electronic invoice is not a mere PDF: it is an invoice issued, transmitted and received in a structured format allowing its automatic processing by accounting software. Article 1, §13 of the Belgian VAT Code (amended by the same law of 6 February 2024) gives a precise definition: "the electronic invoice that has been issued, transmitted and received in a structured electronic form that allows its automatic and electronic processing".
Belgium did not opt for a gradual implementation by company size. The obligation applies to all eligible companies simultaneously since 1 January 2026, with no turnover or headcount threshold. The official portal efacture.belgium.be is maintained by the FPS Finance as a reference point for all practical questions.
The timeline of the obligation
- 1
1 March 2024
B2GElectronic invoicing becomes mandatory for B2G public procurement of at least 3,000 euros excluding VAT. Federal buyers require it below this threshold.
- 2
1 January 2026
B2B mandatoryEntry into force of the B2B obligation for all Belgian VAT taxable persons, with no entry phase by size or sector.
- 3
1 April 2026
PenaltiesEnd of the tolerance period of the first quarter of 2026. The penalties of the royal decree of 8 July 2025 apply from this date.
- 4
1 January 2028
E-reportingE-reporting obligation: B2B invoice data will have to be transmitted in near real time to the FPS Finance via a five-corner Peppol model. End of the flat-rate scheme (art. 56 of the VAT Code), whose taxable persons join the general obligation.
- 5
1 July 2030
EU ViDAEuropean e-invoicing obligation for intra-community transactions, under the ViDA regulation (VAT in the Digital Age).
Who is concerned and who is exempt
The obligation applies as soon as the supplier and the client are both Belgian VAT taxable persons. This covers almost all commercial exchanges between companies and self-employed people established in Belgium.
An often-overlooked point: companies that use the basic VAT exemption (annual turnover below 25,000 euros) are not exempt. The law provides for no size threshold.
| Belgian B2B | B2C | International invoicing | |
|---|---|---|---|
| Structured invoice mandatory | |||
| PDF by email accepted since Jan. 2026 | |||
| Paper accepted | |||
| Peppol network required |
Several profiles are exempt from the obligation to send structured invoices:
- companies carrying out exclusively exempt operations under article 44 of the VAT Code (health professions, teaching, certain financial services)
- taxable persons not established in Belgium without a fixed establishment, even if identified for VAT in Belgium
- taxable persons under the flat-rate scheme (art. 56 of the VAT Code), until the abolition of this scheme, planned by 1 January 2028 at the latest
- taxable persons in bankruptcy
Profiles falling under article 44 and non-established persons without a fixed establishment are also exempt from the obligation to receive structured invoices.
Technical format: Peppol BIS Billing 3.0 and the EN 16931 standard
The royal decree of 8 July 2025 (NUMAC 2025005169) specifies the technical rules. Three pillars structure the obligation:
- The semantic standard: EN 16931-1 (European data model for electronic invoices) and CEN/TS 16931-2 (syntax rules).
- The syntax format: UBL 2.1 in its Peppol BIS Billing 3.0 variant. This specification, known as CIUS (Core Invoice Usage Specification), specifies how to use UBL 2.1 on the Peppol network and makes mandatory certain fields that are optional in the base standard.
- The transmission network: the Peppol network, on a four-corner model. The exchange takes place from supplier to client via their respective access points, with no central governmental hub for B2B.
An alternative format compliant with EN 16931, such as the CII (UN/CEFACT Cross Industry Invoice), may be agreed between the parties. But whatever solution is chosen, every company must keep the technical capacity to issue and receive in the Peppol BIS Billing 3.0 format via the Peppol network: it is the non-negotiable reference format.
Companies access the Peppol network via a certified provider (invoicing software, ERP, or online platform). Direct registration on the network is not possible: it is the provider that manages the connection and assigns the Peppol identifier. The FPS BOSA keeps an up-to-date list of certified providers for Belgium.
The penalties in force since April 2026
The administrative penalties for non-compliance are set by the royal decree of 8 July 2025 (NUMAC 2025005169). They have applied since 1 April 2026, at the end of the first-quarter tolerance period.
1st infringement
Lack of technical means to issue or receive
2nd infringement
Subsequent infringements
These fines penalise the absence of technical capacity to issue or receive structured invoices, that is, non-connection to the Peppol network. They apply per infringement recorded and are added, where applicable, to the proportional fines already provided by article 70 of the VAT Code for content errors in the invoices themselves.
A Peppol invoicing solution included with Monsiegesocial
With your first business address, get one year of YouInv free: unlimited Peppol electronic invoicing, CRM and payment tracking included (value 600 euros excl. VAT).
Tax incentives and practical steps
The Belgian legislator accompanied the obligation with two tax mechanisms to reduce the cost of the transition.
The deduction for digital investment was raised to 20% for SMEs and self-employed people who acquire electronic invoicing software or related digital equipment, from 1 January 2025. In addition, an increased deduction of 120% applies to invoicing software subscriptions and consulting fees linked to e-invoicing compliance, for the taxable periods 2024 to 2027: concretely, an expense of 1,000 euros is deductible up to 1,200 euros.
These measures are detailed by the FPS Finance and the FPS Economy. For the deductible expenses within your SRL, e-invoicing software costs fully qualify.
Monsiegesocial clients also benefit from one year of YouInv free with their first business address: an invoicing software connected to the Peppol network, compliant with the Belgian B2B obligation, with unlimited invoicing, CRM and payment tracking included (value 600 euros excl. VAT).
Bringing yourself into compliance generally follows five steps:
Complying with electronic invoicing: the key steps
Check your invoicing software
Can your accounting or invoicing software issue UBL/Peppol BIS Billing 3.0 files? Most Belgian publishers have integrated this compliance since 2025.
Choose a certified Peppol provider
If your software is not yet connected to the Peppol network, a certified provider connects you. Your Peppol identifier (0208:[CBE number]) is assigned to you at this step.
Configure the receipt of structured invoices
Make sure your system can receive and process incoming UBL invoices automatically. This obligation applies even if you issue few invoices yourself.
Inform your commercial partners
Communicate your Peppol identifier to your suppliers and clients so that exchanges can take place in both directions.
Check your special cases
B2C transactions, international operations, article 44 operations: the efacture.belgium.be portal offers an online tool to check whether your special cases fall under an exemption.
Going further
- Accounting obligations of an SRL in Belgium: how electronic invoicing articulates with your account-keeping obligations.
- VAT for the self-employed in Belgium: exemption, thresholds and returns: the Belgian VAT regime before addressing structured invoicing.
- The official Belgian portal: efacture.belgium.be to check your situation and access the list of certified Peppol providers.



