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E-invoicing in Belgium: the Peppol B2B mandate

Overview​

Since 1 January 2026, all Belgian enterprises liable to VAT must use structured electronic invoices in their transactions with each other — paper and PDF invoices no longer count as valid invoices between Belgian VAT-liable businesses. The official portal states it plainly: "Since 1 January 2026, all Belgian enterprises liable to VAT will have to use structured electronic invoices in their transactions with each other." (FPS Finance — einvoice.belgium.be, checked 2026-08-12)

Source snapshot — Since 1 January 2026, all Belgian enterprises liable to VAT will have to use structured electronic invoices in their transactions with each other Source snapshot captured 2026-08-12 — original

Two authorities share the system: FPS Finance (FOD Financiën / SPF Finances) administers the mandate and runs the official guidance portal, while FPS BOSA has been the Belgian Peppol Authority since 1 January 2016 and operates the Mercurius platform for invoicing the public sector. (FPS Finance FAQ, checked 2026-08-12)

Belgium's model is decentralised interchange, not clearance: invoices travel directly between the parties' access points over the Peppol network. No government platform validates, stamps, or clears domestic B2B invoices, and the official portal publishes no QR-code, hash, or cryptographic-stamp requirement — those concepts are not applicable to the Belgian system.

Mandate status & timeline​

PhaseWho / whatMandatory fromLegal basis
B2G — large contractsSuppliers on public contracts ≥ the EU procurement threshold (EUR 215,000 at the time)Tenders published on/after 1 November 2022Royal Decree of 9 March 2022 [1]
B2G — medium contractsPublic contracts ≥ EUR 30,000Tenders published on/after 1 May 2023Royal Decree of 9 March 2022 [1]
B2G — small contractsPublic contracts < EUR 30,000 (contracts ≤ EUR 3,000 excl. VAT stay exempt)1 March 2024 (postponed from 1 November 2023)Royal Decree of 9 March 2022, as amended [1]
B2B — domesticAll Belgian VAT-liable enterprises, sending and receiving1 January 2026Law of 6 February 2024 [2]
B2B — enforcementConditional penalty tolerance for the first three months of 2026 only (see below); the window closes 31 March 2026tolerance ends 31 March 2026FPS Finance tolerance notice [3]
Self-billing toleranceSelf-billed invoices may be drawn up flexibly where the software vendor is still implementing the functionalityuntil 30 June 2026FPS Finance FAQ [4]
E-reporting (proposed)Near-real-time transactional reporting between Belgian VAT-liable businesses; replaces the annual client listing1 January 2028 (draft law approved by the Council of Ministers 18 July 2026 — not yet enacted)FPS Finance FAQ [5] · Council of Ministers, 18 July 2026

The Q1 2026 tolerance was conditional, not a postponement: FPS Finance stated it would "show tolerance during the first three months of 2026" for enterprises lacking the technical means, provided they could show steps taken "in a timely and reasonable manner" — and "under no circumstances will we grant a general postponement." (tolerance notice, checked 2026-08-12)

  • Law of 6 February 2024 (Belgisch Staatsblad 20 February 2024, numac 2024001635) — inserts art. 53 §2bis into the VAT Code and defines the structured electronic invoice by reference to EN 16931-1 and CEN/TS 16931-2: "an electronic invoice drawn up, sent and received in a structured electronic form enabling its automatic and electronic processing". [2]
  • Royal Decree of 8 July 2025 (BS 14 July 2025, numac 2025005169) — inserts the technical requirements on semantics, syntax and transmission into Royal Decree No. 1 (new art. 13ter) and the fine scale into Royal Decree No. 44; in force 1 January 2026. [6]
  • Law of 10 February 2026 (diverse VAT provisions) — fine-tunes the e-invoicing scope, including the art. 53 §2bis references for non-established taxable persons; FPS Finance commentary in Circulaire 2026/C/43. (Instrument identified; the Fisconetplus permalink is search-driven — search "2026/C/43" on Fisconetplus.)
  • B2G: Royal Decree of 9 March 2022 (BS 31 March 2022, numac 2022020506). [1]

The Law of 6 February 2024 made the mandate's entry into force subject to EU Council authorisation under art. 395 of the VAT Directive; the mandate is in force, but the implementing decision's number is not stated on the FPS portal — cite the law itself as the operative basis.

Scope​

Must issue AND receive structured electronic invoices from 1 January 2026: every enterprise with an active Belgian VAT number transacting domestically with another Belgian VAT-liable business — expressly including:

  • businesses in the small-enterprise exemption scheme (annual turnover ≤ EUR 25,000): "The obligation applies if you make use of the exemption scheme for small businesses" (FPS Finance FAQ, checked 2026-08-12);
  • taxable persons under the special agricultural scheme — "at least for receiving B2B invoices" (same FAQ).

Excluded from issuing: bankrupt taxable persons; businesses performing only art. 44 VAT Code exempt transactions; taxable persons not established in Belgium without a fixed establishment; flat-rate-scheme taxpayers (art. 56 VAT Code). (FPS Finance, checked 2026-08-12)

Excluded from receiving: only art. 44-exempt-only businesses and non-established taxable persons without a fixed establishment (same source).

B2C is out of scope — the obligation does not apply to invoices to private customers. Credit and debit notes are in scope: any document amending a structured e-invoice is itself a structured e-invoice and travels via Peppol, and simplified invoices must also go "(at minimum) via the Peppol BIS format". (FPS Finance FAQ, checked 2026-08-12)

Format & network​

  • Network: "Structured electronic invoices will be sent via a decentralised network called Peppol." (FPS Finance, checked 2026-08-12) — a 4-corner interchange between the parties' access points; no central clearance.
  • Format: participants must at minimum be able to receive Peppol BIS — "an application of the standard EN 16931" (Peppol FAQ); the profile is Peppol BIS Billing 3.0 (corroborated by the European Commission country factsheet).
  • Alternative formats: parties may agree on another structured format instead of Peppol BIS, but only by mutual agreement and only if it complies with the European semantic standard (EN 16931-1 / CEN/TS 16931-2 per the law's definition).
  • B2G: the public sector receives via Mercurius, FPS BOSA's central "mailroom", fully Peppol-aligned, with a web portal for manual submission and track-and-trace. (FPS BOSA, checked 2026-08-12)
  • Peppol participant IDs for Belgian businesses use the KBO/BCE enterprise number — see how to verify a Belgian enterprise number.

Onboarding: how to comply​

  1. Check whether you're in scope with the official self-check tool at einvoice.belgium.be/en/tool.
  2. Pick compliant software or a Peppol service provider. FPS Finance publishes a guide list of compliant software — send-only, send + receive, and full-processing tiers — on the software solutions page; the certified access-point register lives on peppol.org. There is no government registration step for B2B — connecting via a Peppol access point is the whole onboarding.
  3. Claim the tax incentive if you qualify: small SMEs and the self-employed using subscription invoicing packages may deduct 120% of those costs for the 2024–2027 taxable periods (art. 64ter WIB92; FPS commentary in Circulaire 2026/C/46). (FPS Finance, checked 2026-08-12)

BOSA's transitional Hermes bridge (which converted Peppol invoices to PDF-by-email for unequipped receivers) has been wound down in favour of market solutions; its official pages are no longer online, so rely on the software list above rather than Hermes.

Penalties​

Royal Decree of 8 July 2025 inserted a non-proportional fine scale into Royal Decree No. 44 for not possessing the technical means to issue and receive structured electronic invoices, applicable from 1 January 2026 (enforced from 1 April 2026 after the Q1 tolerance):

InfringementFine
FirstEUR 1,500
SecondEUR 3,000
Third and subsequentEUR 5,000

An infringement only counts as a second or subsequent one when it is established at least three months after the previous one — verbatim from the decree: "een inbreuk slechts als een tweede of volgende inbreuk kan worden beschouwd, wanneer deze inbreuk door de administratie is vastgesteld ten vroegste drie maanden nadat de vorige inbreuk [werd vastgesteld]". [6] Whether ordinary proportional VAT fines can stack on top for related invoicing offences is not stated in the fine-scale text itself — check the amended Royal Decree No. 44 annex before relying on the fixed scale being the only exposure.

Source snapshot — Belgian e-invoicing fines: EUR 1,500 first, EUR 3,000 second, EUR 5,000 subsequent infringements, minimum three months apart Source snapshot captured 2026-08-12 — original

Frequently asked questions​

Does the Belgian B2B e-invoicing mandate apply to small businesses under the VAT exemption scheme?

Yes. Businesses using the small-enterprise exemption scheme (annual turnover up to EUR 25,000) are expressly in scope — the FPS Finance FAQ states "the obligation applies if you make use of the exemption scheme for small businesses". Only bankrupt businesses, art. 44-exempt-only businesses, non-established businesses without a Belgian fixed establishment, and flat-rate (art. 56) taxpayers are excluded from issuing. (FPS Finance, checked 2026-08-12)

Can we keep exchanging PDF invoices if both parties agree?

No. Between Belgian VAT-liable businesses, only a structured electronic invoice is a valid invoice from 1 January 2026. Parties may agree on a structured format other than Peppol BIS, but it must comply with the European semantic standard (EN 16931) — a PDF does not qualify. (FPS Finance, checked 2026-08-12)

What fines apply if we cannot send or receive structured e-invoices?

EUR 1,500 for the first established infringement, EUR 3,000 for the second, and EUR 5,000 for the third and subsequent ones, with a minimum of three months between established infringements (Royal Decree of 8 July 2025, in force 1 January 2026; enforced from 1 April 2026 after the Q1 tolerance window). (Belgisch Staatsblad numac 2025005169, checked 2026-08-12)

What is changing in 2028?

A preliminary draft law approved by the Council of Ministers on 18 July 2026 would add mandatory near-real-time electronic reporting of invoice data between Belgian VAT-liable businesses from 1 January 2028 and abolish the annual client listing. It is a draft — it still has to be enacted — and the reporting architecture has not been officially specified yet. (FPS Finance e-reporting FAQ; Belgian Council of Ministers, 18 July 2026)

Recent changes​

  • 2026-07-18 — Council of Ministers approved a preliminary draft law introducing mandatory near-real-time e-reporting of invoice data from 1 January 2028, replacing the annual client listing. (Belgian Federal Government) — see issue
  • 2026-01-01 — Mandatory structured B2B e-invoicing via Peppol in force for all Belgian VAT-liable enterprises; Q1 2026 penalty tolerance ended 31 March 2026. (FPS Finance)

Important websites​