During our recent webinar, our guest speaker, Stefanie Dreher from KPMG, provided an in-depth look at the Belgian e-invoicing mandate and the steps businesses need to take to prepare. Below are some of the key takeaways from that webinar.
As Belgium prepares for its e-invoicing mandate, due to begin on 1 January 2026, businesses are gearing up for a significant change. The mandate, though separate from the EU-wide ViDA (VAT in the Digital Age) initiative, arises from the same challenges and aims to modernise VAT reporting while reducing fraud across Europe. So, it's worth taking a brief look at ViDA for context.
1. Why ViDA?
ViDA’s primary objective is to improve VAT inefficiency and minimise VAT fraud. By improving transparency, ensuring more accurate reporting, and promoting the digital exchange of VAT-related information between businesses and tax authorities, the system aims to contribute significantly to closing the VAT gap, which costs the EU billions of euros in lost revenue every year. More specifically, this will be done by:
- Implementing real-time or near real-time digital VAT reporting (known as DRR) to monitor transactions more effectively.
- Mandating e-invoicing as a standardised way of invoicing for transactions to be reported in the DRR (intra-Community and reverse charge transactions).
Although ViDA has yet to be adopted and the final timelines to be confirmed, Belgium's 2026 deadline for domestic e-invoicing is just the beginning, with more countries expected to follow, driven by the initiative.
2. E-invoicing becoming the norm
Belgium is preparing for mandatory e-invoicing in the B2B context by 1 January 2026. Unlike B2C transactions, which are exempt from the mandate, B2B invoices must follow strict guidelines.
Despite the fact that the obligation is still subject to approval by the EU Council, which is expected in due course, experts foresee no delays.
The key shift is towards structured, electronic invoices that can be processed automatically and digitally. This means that traditional formats such as paper and PDF will no longer be acceptable for B2B invoicing in scope of the new regulation.
But sending and receiving an e-invoice is just the first step in the process. Businesses will need accounting software or tools to process these automatically. Simply having an e-invoice doesn't ensure automatic integration into your accounting system—you need the right technology to handle the data.
3. Belgium & the Peppol network
Offering a dual-track system for businesses to comply with the e-invoicing mandate, Belgium has chosen the Peppol network as its preferred track. Peppol (Pan-European Public Procurement Online) is an international standard that enables the secure and efficient exchange of electronic documents.
The use of Peppol ensures that invoices are sent in a structured, standardised format, allowing for seamless processing across different systems. For Belgian businesses, connecting to Peppol is a crucial step in meeting the e-invoicing mandate. Companies can choose to connect directly through their ERP systems or use third-party providers like Unifiedpost Group to access the Peppol network.
However, participation in the Peppol network is not compulsory. As part of the dual-track approach adopted by the Belgian authorities, businesses can choose an alternative path. In this case, they must agree with their trading partners on the method of e-invoicing and are responsible for ensuring that their invoices comply with the European standard. However, businesses should be aware that even when choosing for another solution, they will need to be ready for Peppol anyway.
By leveraging Peppol, businesses can ensure compliance with both national and international e-invoicing requirements, making it a critical part of the digital VAT transformation.
4. Three essential criteria to consider for Belgian e-invoicing
To determine whether your invoices fall under the upcoming Belgian e-invoicing mandate, it’s crucial to consider three key factors: supplier, customer, and transaction. If you tick all three boxes, then your invoices are subject to the new requirements:
- Supplier: In the role of a supplier, if your business is established in Belgium and has a Belgian VAT number, you must comply with the mandate. This also applies if you are part of a VAT group or a foreign entity with a fixed establishment for VAT purposes in Belgium holding a Belgian VAT number.
- Customer: If your customer is a Belgian VAT registered customer, obliged to provide their VAT number, the transaction falls within the scope of the mandate. It is not required for the customer to be established in Belgium.
- Transaction: The mandate applies primarily to domestic transactions within Belgium. This includes the supply of goods and services that occur within the country and do not cross borders.
These three pillars will help businesses assess whether their invoices are subject to the new regulations and ensure compliance with the e-invoicing mandate. Once you are in scope, the invoicing volumes or annual turnover of your businesses don’t matter.
5. The consequences of non-compliance
Failure to comply with Belgium’s new e-invoicing rules can lead to a number of negative consequences for your business. These include:
- Penalties: Financial penalties may be imposed for issuing non-compliant invoices.
- VAT recovery issues: Customers may face challenges recovering VAT if they do not receive correct e-invoices.
- Payment delays or non-payment: Invoices that do not meet the new requirements may result in customers refusing to pay, affecting your company's cash flow.
6. First things first: conduct a scoping exercise
Our guest speaker, Stefanie Dreher from KPMG, emphasised the importance of conducting a scoping exercise for both the purchasing and sales sides of your business, which should include:
- Checking your VAT registration status in Belgium as a supplier;
- Checking your database for your customers’ and suppliers’ VAT registration status in Belgium;
- Checking the nature and place of supply of your sales and purchasing goods and services.
As mentioned above, all three boxes must be ticked to confirm that an invoice is subject to the e-invoicing mandate.
7. Getting started: key steps to prepare for e-invoicing
To prepare for Belgium's e-invoicing mandate, businesses should follow a few critical steps:
- Information gathering: Start by understanding the latest e-invoicing developments in Belgium and other EU countries, especially if your business operates across borders. Conduct an impact assessment to determine how these regulations will affect your operations.
- Governance: Assess internally who needs to be involved, from key stakeholders to decision-makers. You'll need to secure the necessary resources and budget to implement the required changes.
- ERP/IT strategy: Decide how you will integrate e-invoicing into your existing processes. Will you connect directly to Peppol through your ERP system, or will you use a third party like Unifiedpost Group to do it for you?
By completing these milestones, you can build a solid foundation for compliance and ensure a smooth transition to e-invoicing.
Want to know more?
Download our e-guide with 10 FAQs on the Belgian e-invoicing mandate.
If you have any questions or need assistance in preparing for the upcoming mandate, don't hesitate to contact us. Our team is ready to help you navigate the transition and ensure your business is compliant and future-ready.
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