The TDD Dataset, Peppol Infrastructure, and Your Compliance Roadmap
Belgium has taken the decisive legislative step on the second phase of its VAT digitalisation programme. At a Council of Ministers held by electronic procedure on 18 July 2026 under Prime Minister Bart De Wever, and on a proposal by Finance Minister Jan Jambon, the federal cabinet approved a pre-draft law (voorontwerp van wet / avant-projet de loi) amending the VAT Code to introduce a mandatory electronic reporting obligation and to abolish the annual list of taxable customers.
Until this decision, e-reporting from 2028 existed only as a policy commitment in the 2025 to 2029 federal coalition agreement. The 18 July approval converts that intention into a formal legislative text, now submitted for advice to the Data Protection Authority and the Council of State before entering the parliamentary process.
Where This Sits in Belgium’s Digitalisation Sequence
Belgium’s approach has been deliberately sequential rather than simultaneous. Understanding the order matters, because each phase builds directly on the infrastructure of the previous one.
- 1 January 2026: Structured B2B e-invoicing became mandatory. All Belgian established VAT taxpayers must issue and receive structured electronic invoices for domestic B2B transactions. Peppol serves as the default transmission channel, with alternative networks permitted only where both parties agree and the format complies with EN 16931 or CEN/TS 16931. Even businesses using alternative platforms must retain the technical capability to send and receive via Peppol. A three-month tolerance window applied through Q1 2026, with full enforcement from April 2026 and administrative fines ranging from €1,500 to €5,000 for repeated non-compliance.
- 1 January 2028: Near real-time e-reporting is planned to begin. This is the phase now given legislative form. Rather than a separate filing obligation, it extends the existing invoicing flow by transmitting a subset of invoice data to the tax administration.
- 1 July 2030: The EU’s ViDA Digital Reporting Requirements take effect for intra-Community B2B transactions, at which point Belgium’s domestic system and the European cross-border system converge.
The design logic is that e-reporting is not a second migration. Businesses that correctly implemented e-invoicing in 2026 already possess the Peppol connectivity, structured data, and access point relationships that e-reporting requires.
What the Cabinet Approved
The official communication sets out three substantive elements.
Near Real-Time Reporting of Mandatory Invoice Data
The draft requires that certain mandatory invoice data be reported to the administration in a form of near real-time electronic reporting. This is a subset of the data already contained in the structured e-invoice, transmitted through the same Peppol infrastructure. It is not a duplicate accounting record and it does not replicate the VAT return. The stated purpose is early confirmation of the transaction close to the source, enabling targeted risk analysis.
A Dual-Sided Obligation
This is the most consequential design decision in the text. The reporting must be performed both by the supplier or service provider and by the customer (medecontractant / cocontractant). The official communication describes the bilateral structure as pursuing two objectives:
- Significantly improving taxpayer compliance, notably through the digitisation and computerisation of the data flow, producing more reliable data.
- Providing the administration with faster, more detailed and more reliable information, making existing control techniques more effective through risk analysis, enabling quicker action against specific fraud phenomena, and rendering audit work more efficient.
In architectural terms, this positions Belgium in a five-corner Peppol model: supplier, supplier’s access point, buyer’s access point, buyer, and the tax administration as the fifth corner receiving the reported subset from both sides of the transaction.
Abolition of the Annual Client Listing
The introduction of the e-reporting obligation allows the annual list of taxable customers to be abolished for those taxpayers subject to the new duty. Because the administration receives transaction-level data continuously, the aggregated annual listing loses its purpose. This is presented as a genuine simplification offsetting the new obligation, and it is the clearest compliance win in the package.
For small businesses and for farmers, the obligation to report turnover remains in place. The FPS Finance is still evaluating the most appropriate alternative mechanism for capturing this data.
What Gets Reported: The Dataset
A central question for software providers and in-house systems teams is which fields fall within scope.
The reference specification is Peppol’s ViDA Tax Data Document (version 1.0.0). The FPS Finance considered requesting additional national fields but ultimately chose to remain as close as possible to the ViDA dataset. Professional bodies report that the final Belgian version is expected to contain at most one field more or less than the European baseline.
In practice, the Tax Data Document (TDD) is not a full replica of the original UBL invoice, but a highly specific, tax-oriented subset. Based on the domestic TDD structure, the mandatory elements focus heavily on traceability and tax point accuracy. This includes:
- Specific Structural Identifiers: Requiring VIDA:CustomizationID, VIDA:ProfileID, and the uniquely concatenated VIDA:ID to link the transaction seamlessly.
- Critical Tax Dates: The strict inclusion of the value-added tax point date (cbc:TaxPointDate) alongside standard issue and due dates.
- Dual-Currency Reporting: Clear distinctions between the document currency (cbc:DocumentCurrencyCode) and the VAT accounting currency (cbc:TaxCurrencyCode).
- Party Identifications: Precise supplier and buyer identifications, including electronic addresses (cbc:EndpointID) and registration details (cac:PartyIdentification), rather than exhaustive line-item commercial descriptions.
This restraint carries three practical consequences. It limits development work on the software side. It preserves interoperability with other Member States implementing ViDA. And it avoids forcing Belgian businesses and their advisers into a divergent local specification that would need separate maintenance. The exact Belgian dataset will be fixed in the implementing Royal Decree.
Scope and Exclusions
Transactions exempt under Article 44 of the Belgian VAT Code fall outside the reporting scope. Where an invoice contains both exempt and taxable supplies, only the taxable lines are reported. This means the reporting granularity descends to invoice line level rather than operating purely at document level, a point with direct implications for how ERP and accounts payable systems extract and transmit data.
The 2026 e-invoicing mandate itself excludes B2C transactions, entities making only Article 44 exempt supplies, certain special regimes such as flat-rate taxpayers, and non-established businesses holding only a Belgian VAT registration without a fixed establishment. Belgium has separately been considering an extension of the e-invoicing mandate to non-resident VAT holders from 2028, though this remains unconfirmed.
Timing and the Reporting Window
The reporting trigger on the receiving side is the technical receipt of the invoice, typically by the buyer’s access point software, rather than any manual action. Reporting is independent of whether the invoice has been accepted, approved, or booked. No substantive validation is required before transmission.
The reporting deadline is aligned with ViDA at five days, which the FPS Finance expects to operate as quasi real-time in practice.
Implementation Timeline
- 1 January 2026: Structured B2B e-invoicing becomes mandatory (in force).
- April 2026: Full enforcement of e-invoicing, tolerance window ends.
- 18 July 2026: Council of Ministers approves pre-draft e-reporting law.
- Following approval: Advice sought from Data Protection Authority and Council of State.
- Autumn 2026: Law expected to be published.
- Early 2027: Implementing Royal Decree expected, fixing dataset, deadlines, and exceptions.
- 1 July 2027: ISO 27001 certification requirement for Peppol service providers takes effect.
- 1 January 2028: Planned entry into force of the e-reporting obligation.
- 1 July 2030: EU ViDA Digital Reporting Requirements for intra-Community transactions.
The FPS Finance has acknowledged that a two-year implementation period is not feasible given the political commitment to 1 January 2028, but has stated an intention to provide at least one year of preparation time following publication of the legal framework. Detailed operational guidance through FAQs and circulars is expected well ahead of the entry into force date.
Points of Contention in the Consultation
The dual-sided design has attracted substantive commentary from professional bodies and the business community. These positions are not settled and remain live while the text sits with the Data Protection Authority and the Council of State.
The principal argument advanced against customer-side reporting is that the administration receives two streams of the same underlying data rather than two independent verification points, and that the customer is required to retransmit data it did not create. Related concerns raised include the practical difficulty of meeting a five-day window where invoices arrive through multiple channels and standard triage, validation and dispute cycles routinely take longer, and the reconciliation burden arising from timing differences, credit notes, and retroactive price adjustments creating systematic divergence between reported data and the periodic VAT return.
A further point concerns European harmonisation. ViDA makes customer-side reporting optional rather than mandatory. A Belgian mandate would therefore diverge from the European baseline and, for multinational groups, require a country-specific design for a process that ViDA intends to standardise. On cross-border and Article 194 reverse charge flows, the same transaction data could be reported by the supplier in its own Member State, by the customer in Belgium, and again through the EC Sales Listing under ViDA.
The counterargument from the administration is that bilateral confirmation substantially raises the fraud threshold, because both parties independently confirm the same transaction. The FPS Finance has also emphasised that the receiving side impact remains limited in practice, since the trigger is technical receipt rather than manual intervention and no substantive validation is required.
Professional bodies participating in the BEG WG5 working group have set out four priorities: minimising administrative burden beyond what ViDA already prescribes, securing sufficient preparation time after publication of the law and Royal Decree, developing workable solutions for exceptional cases so that smaller firms are not left interpreting edge cases individually, and maintaining balanced certification of service providers at European level through OpenPeppol’s ISO 27001 requirement without fragmenting the software market through divergent national rules.
The Broader Positioning
Belgium’s move confirms its trajectory towards a continuous transaction control model that keeps it aligned with, and slightly ahead of, the ViDA Digital Reporting Requirements due by July 2030. By building on Peppol and anchoring the dataset to the ViDA Tax Data Document, the design deliberately avoids creating a purely national specification, which preserves the reusability of the investment when the European requirements arrive.
For businesses operating across multiple European jurisdictions, this is the pattern to watch. Belgium is not building a bespoke clearance platform. It is extending an interoperable network already in production, adding the tax administration as a recipient of a standardised data subset. That approach is materially cheaper to implement than a national portal integration, and it is the direction an increasing number of Member States are taking as ViDA approaches.
