Belgium VAT Receipt Lottery: What Could It Mean for GKS 2.0 and HoReCa Businesses?

Belgium has formally launched work on a fiscal receipt lottery linked to the rollout of GKS 2.0. The focus is to encourage consumers to request fiscal receipts (VAT receipts) and reduce VAT fraud, but no lottery-specific POS requirements, technical specifications or official start date have yet been published. 

Belgium’s planned VAT receipt lottery has moved beyond a general policy proposal. The new management contract between the Belgian State and the National Lottery, concluded on 10 September 2026 and in force since 16 September, formally requires the National Lottery, together with the Federal Public Service Finance (FPS Finance), to prepare a proposal for its introduction.

Article 58 of the contract states that the measure is intended to combat VAT fraud by encouraging consumers to systematically request a VAT receipt, with the possibility of winning a prize through participation in the lottery. It also establishes an important connection for the retail-technology sector: implementation of the lottery depends on the phased rollout of GKS 2.0, Belgium’s new Registered Cash Register System.

This is therefore a confirmed government project, but it is not yet an operational lottery and does not currently create a new technical obligation for Horeca businesses, POS providers or Fiscal Data Module providers.

Is the VAT receipt lottery limited to Horeca?

The official wording requires some precision. Article 58 refers broadly to a VAT receipt lottery and does not expressly state that the final legal scope is restricted exclusively to the hospitality sector. What it does say is that implementation depends on the rollout of GKS 2.0. e

That connection currently places Horeca at the centre of the project because GKS is Belgium’s Registered Cash Register System for restaurant and catering activities. Businesses exceeding the annual threshold of EUR 25,000 excluding VAT from restaurant and catering services, excluding drinks for the threshold calculation, are generally required to use GKS. The threshold is assessed per establishment.

For that reason, current reporting describes the future lottery primarily as a measure for restaurant and hospitality VAT receipts. Secondary sources also report that the concept under discussion would allow customers to scan a receipt through a National Lottery application and determine quickly whether they have won.

However, these operational details should not yet be treated as final rules. The management contract itself requires a proposal to be developed and does not define the prize structure, participation limits, application, validation procedure or final sectoral scope.

Why does GKS 2.0 matter?

GKS 2.0 already provides a technical foundation that could potentially support such a system.

Since 1 July 2026, new Horeca businesses that fall within the GKS obligation must immediately use GKS 2.0. Existing GKS users have transitional deadlines depending on when their current cash register was purchased: 1 July 2027 for the oldest systems, 1 July 2028 for systems purchased from 2018 through 2021, and 1 January 2029 for systems purchased from 2022 onwards.

GKS 2.0 also introduces online communication between the renewed Fiscal Data Module (FDM) and the FPS Finance cloud service. Transaction details are transmitted electronically, allowing FPS Finance to use the data for more targeted fiscal controls.

Most relevant for the planned lottery is that GKS 2.0 VAT receipts already contain a QR code. Under the official technical specification, the FDM generates a unique verification URL and sends it to the POS, which must print it as a QR code on the VAT receipt. The URL includes data linked to the FDM, event counter and digital signature. g

This does not, however, mean that the existing GKS 2.0 QR code has already been designated as the lottery mechanism. Media reports describe scanning a QR code through an application, but FPS Finance has not yet published a lottery-specific specification confirming whether the existing GKS verification URL will be reused, extended or supplemented by another identifier.

When could the lottery start?

Some recent reporting refers to mid-2027 as the earliest possible launch period, linking the timing to the number of businesses that will have migrated to GKS 2.0.

This should currently be treated as an expected timetable rather than an official implementation date. Article 58 contains no fixed start date. It states only that implementation depends on the phased GKS 2.0 rollout and that the necessary agreements between the Belgian State and the National Lottery must still be concluded.

Likewise, reported concepts involving frequent smaller prizes, immediate results through an application and subsequent validation before payment have not yet been incorporated into published fiscal or GKS technical rules.

What is the expected impact on Horeca businesses and GKS 2.0 providers?

At present, Horeca businesses do not need to change their GKS 2.0 configuration because of the lottery project. Their obligation remains to comply with the existing GKS rules and applicable migration deadline.

POS and FDM providers should nevertheless monitor the project. The current GKS 2.0 technical documentation already regulates the generation and printing of the verification QR code, while the official GKS technical page—updated with technical and certification material in September 2026—does not currently list a separate lottery-specific technical specification.

Providers should therefore not modify the existing VAT receipt QR code or implement presumed lottery functionality based only on media descriptions. Any development should follow future requirements from FPS Finance and the National Lottery.

From a fiscalization perspective, the main unresolved question is how the future lottery will interact with an already certified GKS 2.0 transaction flow. If the existing FDM-generated verification URL can be used without changing the fiscal process, the POS impact may be relatively limited. If additional data, interfaces or receipt elements are required, software and FDM providers will need to assess the resulting development and certification implications.

What should affected businesses do?

Horeca businesses must continue following the existing GKS 2.0 requirements and migration timetable; there is currently no separate lottery obligation. POS and FDM providers should monitor FPS Finance and the official GKS portal for technical specifications, particularly any changes concerning the VAT receipt, verification URL or QR code. Businesses may prepare internally for the project, but should not treat reported app functionality, prize structures or a mid-2027 launch as final requirements.

The principal legal basis is Article 58 of the new management contract between the Belgian State and the National Lottery, published in the Belgian Official Gazette. It can be accessed here - Source

The existing fiscal and technical framework is documented by FPS Finance through the official GKS 2.0 portal.  

Tara Nedeljković, Team Lead of Legal Consultants at Fiscal Solutions

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