The Belgian government has formally put its e-reporting plan before Parliament. The bill, now filed in the Chamber of Representatives, turns the policy approved by the cabinet in July into legal text. It defines who reports, what they report, through which channel and from which date. The annual listing of VAT-registered customers is replaced by continuous, invoice-level reporting, and both the supplier and the buyer report every in-scope transaction over the Peppol network.
This article looks only at what the bill itself says and what remains open.
| Date | Milestone |
| 17 August 2026 | Data Protection Authority issues its opinion on the draft |
| 30 September 2026 | Council of State issues its opinion on the draft |
| 26 October 2026 | Bill signed by the government |
| 27 October 2026 | Bill filed in the Chamber of Representatives |
| 1 January 2028 | E-reporting applies; annual customer listing abolished for businesses in scope |
| 31 March 2028 | Last annual customer listing due, covering 2027 transactions |
| 30 June 2030 | End of the transitional listing regime for non-established businesses |
| 1 July 2030 | EU ViDA digital reporting starts; national systems must meet ViDA conditions |
From E-Invoicing to E-Reporting
Since 1 January 2026, businesses established in Belgium must exchange structured electronic invoices with each other. The tax administration (FPS Finance) has not yet been part of that exchange. The bill changes this: selected data from each structured invoice will also go to the administration, shortly after the invoice is issued or received.
The government presents the change as an evolution of the tools it already has, not a new right of access. Today, the administration builds its picture from two sources: the annual customer listing that businesses send, and its power to request invoices during audits. E-reporting gives it the same information in a faster, more detailed and machine-readable form. The stated goals are earlier detection of VAT fraud, carousel fraud in particular, automated risk analysis by sector and company size, and a smaller VAT gap. The explanatory memorandum points to Italy as evidence that such a system works.
What the Bill Changes
The annual customer listing goes
The bill rewrites the provision of the VAT Code that requires the annual listing of VAT-registered customers. For businesses subject to e-reporting, the listing ends with transactions made in 2027. Instead of one aggregated figure per customer per year, the administration receives transaction data invoice by invoice, on a continuous basis.
The administrative tolerances that applied to the listing do not carry over. The current practice of leaving out invoices with a taxable amount of €250 or less no longer applies, and no transaction types are exempt based on their nature.
Only data the invoice must already contain
Following the Data Protection Authority’s opinion, the bill states that the government may require only data that VAT rules already make mandatory on the structured invoice. It cannot add new data categories through the implementing decree. In its explanations to the Council of State, the government indicated that the reported data will include the invoice date and number, both parties’ VAT numbers, and the core transaction and tax details of the invoice.
Data reported “as issued”
Because reporting happens almost immediately, the data is reported in the form in which the invoice was issued and received. This comes before the buyer has checked the invoice against its order or delivery (“business validation”) and before any correction. The rules on corrections do not change: a credit note or corrective document is reported in the same way as the original invoice it amends.
Who Reports
Two sides of the same transaction
Unlike the annual listing, which only the supplier filed, e-reporting is dual-sided. The supplier reports the sale, and the Belgian business customer reports the same transaction as a purchase. In self-billing, the customer who issues the invoice on the supplier’s behalf is the one that reports on the purchase side. A third party, such as a service provider, may report on behalf of either party.
The bill is clear on how mismatches are treated. A difference between the two reports is not in itself proof of an irregularity, and it cannot automatically trigger a tax adjustment. Timing gaps, disputes and corrections are expected. Tolerances will apply, and only significant or persistent differences will lead to further checks by an official.
Scope in brief
The obligation covers domestic B2B supplies by businesses established and VAT-registered in Belgium where a structured e-invoice is required. In practice, this is the same population as the 2026 e-invoicing mandate. A few specific rules apply:
- VAT groups: the reporting obligation falls on each individual member, not on the group. One member’s failure does not raise another member’s fine, and members are not jointly liable for each other’s penalties. Transactions between members, documented by the specific internal document, are also reported.
- Farmers under the flat-rate agricultural scheme: they do not report their own supplies under that scheme. Their customer reports instead, based on the structured purchase document it issues.
- Businesses making only VAT-exempt supplies are outside the scope, as are exempt transactions in general.
- Professionals bound by professional secrecy, such as lawyers, remain fully in scope, as they are today for the annual listing.
Non-Established Businesses
Belgium cannot yet require foreign businesses that only hold a Belgian VAT number to issue structured e-invoices. The bill therefore sets out a transitional regime until ViDA takes effect:
- Non-established supplier with a Belgian VAT number: no mandatory e-reporting. It keeps filing the annual customer listing for transactions made from 1 January 2028 to 30 June 2030, or it can opt into e-reporting for all transactions under that VAT number and be released from the listing.
- Belgian supplier selling to a non-established customer with a Belgian VAT number: the supplier must still report, even though it is not required to send that customer a structured e-invoice. It can generate the structured invoice data internally and report it without sending the invoice to the customer.
- Non-established customer: no reporting obligation on its purchases.
- Belgian customer receiving a structured invoice from a non-established supplier: not required to report, but may report voluntarily. The bill treats such voluntary reporting as made under the law, which protects both the business and the administration.
How Reporting Will Work
The channel: Peppol, not a government portal
The bill states that data is sent through the Peppol network, to an electronic address designated by the administration. FPS Finance will not build a separate application or API. The existing exchange model gains one more recipient: the tax administration.
A typical domestic transaction will flow as follows:
- The supplier’s system creates the structured invoice.
- The supplier’s Peppol Access Point delivers the invoice to the buyer’s Access Point, as it does today.
- The supplier’s side extracts the required data and sends it over Peppol to the FPS Finance address.
- On receipt, the buyer’s side extracts the same data and sends it to FPS Finance.
- FPS Finance compares the two reports and runs its risk analysis.
The bill leaves the exact message format to the implementing decree. The Peppol community has been piloting a dedicated tax data message for this kind of reporting flow, but the bill does not commit to a specific format.
Deadline: five calendar days at most
The exact reporting deadlines will be set by royal decree. The bill caps them at five calendar days, with exceptions for cases of force majeure that the decree will define. The government explains that the five-day ceiling matches the longest deadline allowed under ViDA for national reporting systems, and that the decree will follow the ViDA deadlines as closely as possible. Under ViDA, the issuer transmits data when the invoice is issued, and the recipient within five days of receipt. Suppliers should therefore expect a shorter deadline than five days.
What Does Not Change
- The periodic VAT return stays. E-reporting does not cover sales to consumers or the accounting adjustments that drive deductible VAT, such as mixed or partial business use.
- Intra-EU transactions stay out. They remain in the EC Sales List until ViDA replaces it with EU digital reporting on 1 July 2030.
- Invoice format rules stay. Peppol BIS over the Peppol network remains the default for e-invoices. Other EN 16931 compliant formats and channels remain possible by agreement between the parties. Reporting, however, goes through Peppol.
Open Points
The implementing decree. A draft royal decree setting the data fields, deadlines and technical details already exists. It can only be sent to the Council of State once Parliament has adopted the law. The government told the Council of State that one calendar year is a reasonable implementation period and that it will act if delays put this at risk.
EU law compatibility. The Council of State expressed doubts about whether parts of the regime fit the current VAT Directive. Its main concern is the cases where reporting is required without an e-invoicing obligation. The government disagrees, considers that no EU derogation is needed, and has not followed the Council’s opinion on this point. If Parliament keeps the text as it is, this remains a possible point of legal challenge.
Administration readiness. The FPS Finance project started in March 2025. The administration says it aims to be ready to receive and process the data on 1 January 2028. The government expects most of the technical work to fall on service providers rather than businesses.
Parliamentary adoption. The bill still has to pass the Chamber. Changes during debate are possible, but the core design has been stable since the July cabinet approval.
What Businesses Should Do Now
Companies already exchanging structured invoices over Peppol are well placed, because the data to be reported is already in their invoices. The work lies in making sure that every issued and received invoice, credit note and internal VAT group document triggers a report within the deadline. Purchase-side processes need particular attention, since many companies have not treated incoming invoices as a reporting event until now. Businesses should also review their Belgian VAT registrations, especially where a non-established entity’s transactions or a VAT group structure are involved.
As a certified Peppol Access Point, RTC follows the Belgian implementing rules closely and will support both outbound and inbound reporting as the technical specifications are published.
