General subject related
Scope
The requirement applies to all domestic B2B transactions where the place of supply is in Belgium, including intra-group VAT transactions. Exemptions include:
- B2C transactions
- VAT-exempt transactions
- Transactions outside Belgium
- Non-VAT-registered entities
- Bankrupt or foreign VAT-registered taxpayers
Format Requirements
Invoices must be issued in the Peppol BIS format, or another format compliant with EU standards (EN 16931). Regardless of the chosen format, all taxpayers must be technically capable of issuing and receiving Peppol BIS-compliant invoices.
Penalties
Non-compliance with technical e-invoicing capabilities will incur:
- €1,500 for a first offense
- €3,000 for a second offense
- €5,000 for repeated offenses
Additional penalties ranging from €50 to €5,000 apply for other violations like late or incorrect invoicing.
Belgium’s decree enforces a broad and clearly defined B2B e-invoicing obligation, in line with EU digital VAT reforms. By mandating Peppol BIS readiness even when using alternative formats, the law prioritizes interoperability and auditability. The tiered penalties reinforce the need for early technical alignment to avoid disruptions and fines starting in 2026.
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