Belgium E-Invoicing: New Penalties for Non-Compliance Effective 2026

On July 8, 2025, Belgium confirmed that mandatory structured e-invoicing for domestic B2B transactions between VAT-registered taxpayers will begin on January 1, 2026, as per the Law of 6 February 2024. The obligation excludes B2C transactions, exempt or foreign transactions, and non-VAT-registered or bankrupt entities. Invoices must use the Peppol BIS format or a EU-compliant alternative, but all taxpayers must still support Peppol. Penalties for non-compliance range from €1,500 to €5,000, with additional fines for late or incorrect invoicing. The decree supports EU VAT digitization goals and stresses the urgency for technical readiness.

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.