1. Overview
Belgium’s implementation of the Standard Audit File for Tax (SAF-T) is on a purely voluntary basis, distinguishing it from other European countries that have set mandatory requirements. Below is a concise overview of what businesses need to know if they choose to adopt SAF-T.
1.2. Voluntary Basis
While several countries enforce SAF-T as a compulsory format, Belgium opts for a “voluntary adoption” strategy. Companies with preexisting digital audit files can submit them without additional compliance pressure.
2. Scope of the SAF-T BE
SAF-T is expected to cover records related to VAT, corporate tax, and other direct and indirect taxes. Customs-related records are explicitly excluded.
3. Who Falls Under the Scope?
All Belgian taxpayers dealing with VAT, corporate tax, and other direct or indirect taxes have the option to utilize SAF-T on a voluntary basis. No additional taxpayer categories face new mandates under the current framework.
4. Timeline for SAF-T Implementation
• 2025 Developments: The Federal Public Service (FPS) Finance will clarify technical requirements and portal functionalities in 2025.
• No Immediate Mandatory Deadline: Since the program is voluntary, there is no fixed timeline to begin submissions.
5. Submission Frequency
When a company decides to submit SAF-T files voluntarily, they must do so once at the close of the financial year, synchronizing with their annual reporting cycle.
6. Penalties for Non-Compliance
As SAF-T adoption is optional, there are no additional penalties for non-participation. However, businesses must still comply with general tax requirements to provide accurate records upon request.
7. Portal for Submission
• MyMinFin Portal: FPS has planned the submission through MyMinFin Portal for all SAF-T files.
8. Key Technical Insights
8.1. Data Format
• OECD v.2 Alignment: Belgium’s SAF-T format (SAF-T BE) follows the XML-based schema recommended by the OECD (v.2).
8.2. SAF-T File Structure
Under OECD v.2 guidelines, each SAF-T file generally includes:
1. Header
2. Masterfiles
3. GeneralLedger
4. SourceDocuments
For the initial voluntary phase, the Ministry of Finance focuses on the Header, Masterfiles, and GeneralLedger.
Belgium’s voluntary SAF-T approach allows businesses to modernize their tax reporting at their own pace. While the immediate pressure to adopt is minimal, organizations that proactively align their systems with the OECD-based SAF-T standard may benefit from smoother audits and future compliance. As a global e-invoice and e-reporting service provider, we will continue to monitor developments and stand ready to help businesses navigate this evolving landscape.
Disclaimer: The information in this article is current at the time of writing and may be subject to change based on regulatory updates.
