Belgium's e-invoicing rules: Who is obligated to comply and from when?

Belgium is preparing to introduce electronic invoicing that will affect certain suppliers, customers, and transactions from January 1st, 2026, as explained below. The entry into force of the rules for e-invoicing in Belgium is foreseen to commence on January 1st, 2026, whereas the obligation to issue a structured electronic invoice requires the meeting of the following three factors, explained below.

The supplier must be a VAT-taxable person established in Belgium, with some specifically defined exceptions, such as:

• A taxable person who exclusively carries out transactions exempted under Article 44 of the Belgian VAT Code is not included in the obligation.
• A taxable person applying the flat-rate scheme of Article 56 of the Belgian VAT code
• Taxable persons in a state of bankruptcy.

The customer must be a taxable person who has the legal obligation to provide its Belgian VAT number to the supplier for the purchases made, with the exception of:

• A taxable person who only carries out transactions that are explicitly exempted under Article 44 of the Belgian VAT code and do not allow a right of VAT deduction

Taxable transactions: the transactions for which a structured electronic invoice must be issued concern only supplies of goods and services that must be considered to be located in Belgium for VAT purposes, except for:

• Supplies of goods that imply a shipment of goods outside Belgium for which the customer does not need to provide a Belgian VAT number
• Taxable transactions are exempted under Article 44 of the Belgian VAT code.

Where the issuance of a structured electronic invoice is mandatory (currently planned for B2B only), the customer is obliged to accept, i.e., cannot refuse to receive a structured electronic invoice.

It is important to keep in mind that:

• The e-invoicing law does not address mandatory electronic reporting (but it is expected that this will be addressed at a later stage).
• The regulations in this field do not apply to business-to-government (B2G) or business-to-consumer (B2C) transactions, but rather only B2B.

A separate EU framework for electronic invoicing already exists for B2G transactions. If needed, the rules could be further amended to be fully compatible with the final rules adopted at the EU level in the future.