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Public Belgium Author: Ljubica Blagojević
Belgium’s Royal Decree No. 2025005169 requires all VAT-registered businesses to use structured electronic invoices for B2B transactions starting 1 January 2026. Invoices must be sent via the PEPPOL network using EU standard EN 16931. While alternative EU-compliant formats may be used with mutual consent, all businesses must still support PEPPOL.VAT rounding is only allowed on the total amount, not per line item. Non-compliance with technical requirements will result in escalating fines (€1,500, €3,000, €5,000). Late or non-compliant invoices fall under existing VAT penalties. This reform aligns Belgium with EU digital invoicing standards, enhances interoperability, and prepares the ground for future real-time e-reporting. Businesses are encouraged to adopt PEPPOL early to ensure compliance and avoid penalties.
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Content accuracy validation date: 04.08.2025
Content accuracy validation time: 10:36h

Main Requirements and Implications:

  • Mandatory Format and Channel:
    Businesses must issue machine-readable structured e-invoices via the PEPPOL network, using EU-compliant formats (EN 16931).
  • Alternative Formats Allowed:
    Other EU-compliant formats may be used only if both parties agree, but all taxpayers must remain technically capable of sending and receiving via PEPPOL.
  • VAT Rounding Rules:
    VAT must only be rounded on the total amount, not per invoice line.
  • Penalties for Technical Non-Compliance:
    Failure to maintain e-invoicing capabilities triggers fines:
    • €1,500 for the first offense
    • €3,000 for the second
    • €5,000 for each subsequent violation
  • Invoice Timeliness and Format Enforcement:
    Delays or format issues fall under existing VAT penalty regimes, reinforcing the need for timely, compliant invoice exchange.

This decree marks a significant shift toward real-time digital compliance, encouraging early adoption of the PEPPOL network and technical readiness. It strengthens invoice standardization, boosts cross-border interoperability, and minimizes VAT fraud risks—paving the way for future e-reporting requirements.

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