The Belgian Federal Public Service Finance has released new guidelines for the upcoming mandatory B2B e-Invoicing requirement, set to take effect on January 1, 2026. This directive will obligate all business-to-business transactions to utilize structured electronic invoices, although it does not yet mandate reporting these invoices to tax authorities.
Key Highlights of the 2026 e-Invoicing Mandate
Scope of Transactions: From January 1, 2026, structured electronic invoices will be mandatory for nearly all transactions between Belgian VAT-registered companies. This requirement excludes B2C transactions, where goods or services are provided to individuals for personal use.
Structured E-Invoice Format: Invoices must comply with the EN 16931 format, which facilitates automatic and electronic processing. Specifically, they must be formatted according to the Peppol-BIS standard. Consequently, PDF invoices will no longer be accepted after December 2025.
Technical Requirements: The guidelines also specify technical rules to ensure the authenticity of origin, integrity of content, and readability of e-Invoices. This ensures that the invoices are compliant with the stringent requirements of VAT legislation.
International Invoicing: For international transactions involving either a shipper or recipient outside Belgium, electronic invoicing is permitted only with the recipient’s agreement. The format and method of transfer must be mutually agreed upon by both parties.
Legislative Framework: The legislation mandating B2B e-Invoicing has been gazetted and is expected to be fully adopted by January 1, 2026. However, Belgium is awaiting approval from the European Commission to enforce this mandate, as it requires a derogation from the EU VAT Directive (Articles 218 and 232).
Implementation and Long-Term Vision
Initial Implementation: Initially, the mandate will apply to Belgian-resident companies, local subsidiaries of foreign firms, and non-resident businesses with VAT registration and fixed establishments in Belgium. The system will use the Peppol 4-corner model, with the option for other compliant exchange platforms by mutual agreement.
Future Outlook: Belgium aims to transition to a 5-corner Peppol model, incorporating near-live e-reporting to replace the annual customer listing report. This is part of a broader effort to reduce the VAT Gap, estimated by the EU to be €4.8 billion annually. This strategy aligns with the EU VAT in the Digital Age initiative, which aims for a standardized e-Invoicing system across the EU by 2030.
Current Practices: Currently, B2B e-Invoicing is allowed without the need for paper invoices, provided both parties agree and maintain secure controls over the issuance, receipt, and storage processes.
By understanding and preparing for these regulatory changes, businesses can ensure compliance and optimize their invoicing processes, paving the way for more efficient financial operations.
