General subject related
- Peppol BIS Confirmed as the Standard Format
- The Peppol BIS (UBL version) is confirmed as the default format for structured e-invoices under the EU norm EN 16931.
- Businesses using ERPs or accounting systems connected to Peppol and issuing invoices in this format will be compliant.
- Peppol is considered “future-proof,” aligning with upcoming EU reforms, including e-reporting by 2028.
- Alternative formats are allowed, but only if both parties agree and the format meets EU standards.
Example: B2G suppliers already using another compliant network may continue doing so post-2026, with mutual agreement.
- Penalties for Non-Compliance
- From January 2026, all VAT-registered businesses must be technically able to issue and receive e-invoices.
- A new fixed-penalty regime is introduced via Royal Decree No. 44:
- €1,500 for a first offense
- €3,000 for a second (if over 3 months later)
- €5,000 for each subsequent offense
- These apply specifically to failure to have the required technical capacity.
- Other invoicing penalties (e.g., incorrect content or format) remain in force.
- Additional Provisions and Forthcoming Guidance
- The Decree also addresses issues like VAT grouping and rounding rules.
- Further clarification is expected on self-billing, and cases where only one party is technically ready for e-invoicing.
Important Milestones:
- October 2021:
The Belgian government announced its intention to mandate B2B e-invoicing, aiming to reduce VAT fraud and recover part of the €4.4 billion VAT gap (12.3% lost in 2019). - November 2022:
Mandatory B2G e-invoicing introduced for public contracts over €215,000, using structured formats via Peppol. - March 2023:
The B2G mandate expanded to cover most public sector contracts. Suppliers must issue e-invoices compliant with EU standard EN 16931 via the Peppol network. - December 2023:
Belgium published a draft law to extend e-invoicing obligations to B2B, requiring Peppol-certified providers for compliant invoice exchange. - July 2025:
A Royal Decree formally confirms the B2B mandate from January 1, 2026, requiring invoices to be structured, Peppol-based, and EN 16931 compliant.
Noncompliance will result in administrative fines starting at €1,500.
Belgium’s decree sets a clear path for implementing mandatory B2B e-invoicing, prioritizing interoperability and compliance with EU standards. Peppol BIS is positioned as the default solution, but with flexibility for agreed alternatives. The introduction of escalating fixed penalties underlines the importance of readiness, making early technical alignment essential for businesses operating in Belgium. Further operational details are anticipated before full enforcement in 2026.
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