Belgium E-Reporting: Near Real-Time B2B Reporting Proposed for 2028?

Belgium has approved a preliminary draft introducing near real-time reporting of invoice data, currently expected from 2028. The proposal builds on mandatory B2B e-invoicing, while there are no current proposals about that ordinary B2C retail receipts for this upcoming change.

Belgium has moved to the next stage of its VAT digitalisation programme, where the Council of Ministers approved a preliminary draft law that would introduce near real-time electronic reporting of certain invoice data to the Belgian VAT administration. The proposal is not yet final legislation - it has been sent to the Data Protection Authority and the Council of State for review, and further legislative steps are still required.

The measure follows Belgium’s mandatory structured B2B E-Invoicing regime, which has applied since January 1st, 2026. Under the current system, qualifying domestic transactions between Belgian VAT-taxable businesses must be invoiced electronically in a structured format. The government’s official E-Invoicing portal confirms that invoice information is not yet automatically sent to the tax administration in this first phase.

The proposal would add that reporting layer to the previous requirement. Certain mandatory invoice data would be transmitted to the tax authorities on a near real-time basis, giving the administration access to transaction-level information much earlier than under traditional VAT controls.

What would change under the proposed E-Reporting system?

For the planned system, it is intended that reporting would take place from both sides of the transaction: the supplier or service provider and the customer would each have a reporting role. The Belgian’ government expects this to improve data reliability and make it easier to compare information submitted by both parties.

For the tax administration, faster access to invoice data is intended to support risk analysis, identify inconsistencies earlier and allow quicker action against VAT fraud. For businesses, the change would move part of VAT compliance closer to the time when invoices are issued and received, rather than relying mainly on periodic VAT returns and later audits.

The proposal would also remove the annual list of taxable customers for taxpayers subject to the new reporting obligation. This should not be read as an immediate general abolition of the annual customer listing. Its removal is linked to taxpayers covered by the future regime.

The entry into force is currently planned for January 1st, 2028, but the date and detailed rules remain subject to further confirmation. The exact data elements, reporting deadlines, exceptions and technical implementation are expected to be defined later.

Does the proposal also cover B2C retail sales or impact it?

Based on the actual proposal, B2C retail transactions will not be included in the proposed Belgian E-Reporting obligation.

The government’s official E-Reporting FAQ states that the measure announced in the federal coalition agreement concerns transactions between two Belgian companies subject to VAT. The July 2026 government announcement also presents E-Reporting as a continuation of the structured E-Invoicing obligation introduced between taxable persons from January 1, 2026.

This distinction is important for retailers because a standard consumer sale at the checkout, supported by a consumer receipt or, where applicable, a receipt from a Registered Cash Register System, should not currently be treated as a transaction that automatically falls under the future invoice e-Reporting regime.

A retailer may still have transactions within the B2B invoicing framework, for example where a business customer purchases goods and requires a structured invoice. Those invoice flows are the area that retailers, ERP providers and E-Invoicing providers should monitor most closely for this area.

Impact on invoicing systems

For businesses already issuing and receiving Belgian structured B2B invoices, the proposal could turn the existing invoice flow into the basis for an additional tax reporting process. The main operational issue will therefore be data quality and consistency across invoicing, ERP, accounting and VAT reporting systems.

If invoice information reaches the tax administration shortly after the transaction, discrepancies may become visible earlier. Differences in VAT codes, customer VAT numbers, invoice values, credit notes or reporting periods could be identified through automated cross-checks rather than only during a later audit. DLA Piper similarly notes that inconsistencies between invoice data, VAT returns and other reported information are likely to become easier for the authorities to identify.

Retailers with B2B sales originating in stores should pay particular attention to how the POS, central invoicing platform and ERP system interact. The proposal does not currently create a new B2C-POS reporting obligation, but a B2B sale initiated at the checkout may ultimately feed into the structured invoice and future E-Reporting process. Businesses should therefore distinguish consumer receipt flows from B2B invoice flows correctly.

From a retail compliance perspective, the main challenge is likely to make sure that the same transaction is represented consistently throughout different systems. The fact that both supplier and customer are expected to report also increases the importance of matching data. Businesses should nevertheless avoid designing technical solutions around assumptions that have not been confirmed, because the reporting dataset and transmission rules are still pending.

What should affected businesses prepare for?

Businesses do not yet need to implement a final E-Reporting solution, because the preliminary draft still has to complete the legislative process and the technical rules are not final. However, companies with Belgian B2B invoice flows should already review whether their systems can support automated extraction and transmission of structured invoice data.

Retailers and solution providers should review the quality of customer VAT data, invoice and credit-note processing, VAT coding, links between POS and ERP systems, and reconciliation between invoices and VAT returns. They should also monitor the final legal scope, including exclusions, reporting deadlines and technical specifications.

The official source is the https://news.belgium.be/nl/invoering-van-de-verplichting-tot-elektronische-rapportering-factuurgegevens , which confirms the preliminary draft and the planned bilateral near-real-time reporting model. Belgium’s official E-Reporting FAQ further explains that the planned reporting concerns transactions between Belgian VAT-liable businesses and is intended to replace the annual customer listing.

Tara Nedeljković, Team Lead of Legal Consultants at Fiscal Solutions

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