Belgium’s tax authorities have confirmed that the mandatory B2B e-invoicing regime will begin on January 1, 2026, with no transitional delay, and urged businesses to finalize their Peppol-based readiness. The updated FAQ clarifies key rules on invoice dating, input VAT eligibility, written opt-outs, Hermes phase-out, and verification of public entities via the CBE portal
Belgian tax authorities provide clarifications on the upcoming mandatory B2B e-invoicing
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Belgium
Author: Vukašin Santo
Category:
Fiscal subject related
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2025
Content accuracy validation date:
21.10.2025
Content accuracy validation time:
10:09h
Belgian tax authorities have released an updated FAQ document providing crucial clarifications on the country’s upcoming mandatory B2B e-invoicing regime, which officially takes effect on January 1, 2026.
Despite speculation about possible transitional leniency, authorities reaffirmed that the start date remains unchanged, urging companies to finalize their preparations for structured e-invoicing in the coming weeks.
The updated FAQ outlines practical guidance on implementation, compliance risks, and the phase-out of existing tools such as Hermes.
Below are the main updates:
1. Invoice date determines applicability
From January 1, 2026, all invoices issued or sent on or after that date must be structured electronic invoices, even if the underlying transaction occurred earlier. Credit notes must follow the format of the original invoice.
2. Input VAT deduction requires e-compliant invoices
Businesses can only claim input VAT if they receive a compliant structured e-invoice for transactions within the mandate’s scope. Non-structured invoices may jeopardise the right to deduct VAT, except in limited “substance-over-form” cases.
3. Written opt-out agreement recommended for Peppol exemptions
While invoices must generally be transmitted via Peppol, companies may mutually agree to use alternative formats compliant with EN16931. Such agreements should be explicit and in writing to avoid disputes or compliance risks.
4. Hermes platform to be decommissioned
The government’s Hermes e-invoicing solution will be discontinued on December 31, 2025. Businesses using Hermes must transition to Peppol-compatible providers before year-end.
5. Easier identification of public entities for B2G invoicing
Companies can now verify whether a client is a public contracting authority subject to B2G e-invoicing through the Crossroads Bank for Enterprises (CBE) portal.
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