Belgium: Does Rejecting an E-Invoice Through Peppol Count as a Legal Dispute?

Belgium’s mandatory B2B e-invoicing does not make a received invoice automatically correct. A rejection status in software may not protect a buyer’s position: businesses should raise clear, timely objections with suppliers and retain evidence of communication.

An invoice received through Belgium’s Peppol-based E-Invoicing system can be technically valid yet commercially incorrect. A retailer may disagree with the quantities billed, the price or whether goods were delivered. Marking the invoice as “rejected” in accounting software does not necessarily demonstrate that the supplier received an objection.

An article published by Auxadi on October 21, 2026, highlights this distinction. It is a reminder of existing invoice-dispute principles, not a new Belgian law. For retailers, hospitality operators and software providers, the practical issue is connecting invoice processing with supplier communication and evidence of disputes.

Since January 1, 2026, structured E-Invoices have been required for most domestic business-to-business (B2B) transactions between Belgian VAT-liable enterprises. Belgium uses the Peppol network as the standard exchange route, although certain agreed alternatives are permitted. An ordinary PDF sent by email does not meet the structured E-Invoicing requirement for transactions within its scope.

The requirement concerns invoice format and exchange. It does not establish that every amount on a successfully received invoice is correct or resolve disagreements over the underlying supply.

Belgian guidance also distinguishes B2B invoices from business-to-consumer (B2C) sales, which fall outside this mandate. However, businesses selling mainly to consumers may still need to receive structured E-Invoices from suppliers.

Belgian Civil Code Article 8.11, paragraph 4, provides that an invoice accepted by a business, or not disputed within a reasonable time, may serve as evidence against that business of the alleged transaction, unless contrary evidence is produced. This is a rebuttable evidentiary rule, not automatic acceptance of every electronically delivered invoice.

Three events must be distinguished: successful E-Invoice transmission, an internal accounting decision to reject it, and communication of a reasoned objection to the supplier.

Peppol supports a standardized Invoice Response allowing buyers to notify suppliers that invoices are under query or rejected, including an explanation. However, this functionality is not necessarily implemented in every system.

The Peppol specification states that an Invoice Response has no legal power and does not itself change contractual payment obligations. Therefore, a rejection status should not replace a properly documented dispute, although a response actually delivered to the supplier may provide supporting evidence.

A dispute should identify the invoice number and date, explain the contested amount or item, and refer to supporting documentation such as purchase orders, contracts or delivery records.

Common grounds include duplicate billing, incorrect quantities, and unperformed services or goods that do not match the order.

Written notification directly to the supplier provides a record of the objection. Email may be sufficient where delivery or acknowledgement can be demonstrated, while registered post may be appropriate depending on contractual requirements.

If a Peppol Invoice Response is used, businesses should verify that the message was actually transmitted rather than relying on an internal status.

Belgian law refers to a reasonable time for invoice objections, without prescribing a universal seven-day or fourteen-day deadline. The appropriate period depends on the transaction, circumstances and contractual terms. Businesses should therefore examine incoming invoices promptly and check any agreed dispute procedures.

For retail chains processing numerous supplier invoices, automated workflows can create gaps between operational verification and accounting approval.

Goods-received records may reveal missing products while the accounting system has already imported the E-Invoice for payment. Businesses should connect discrepancies with invoice reviews, prevent automatic approval of contested amounts and preserve supplier correspondence.

E-Invoicing and enterprise resource planning (ERP) software providers should distinguish technical delivery acknowledgements from commercial invoice statuses. Where Peppol Invoice Response is supported, users should understand whether selecting “reject” sends an external message or only changes an internal record.

Systems should also preserve links between disputed invoices, subsequent credit notes, and replacement invoices where applicable.

For restaurants and hospitality businesses, supplier-invoice disputes remain separate from sales receipt requirements. Belgian guidance confirms that structured B2B invoices do not replace receipts required under the Registered Cash Register System (GKS).

Consequently, disputing a supplier invoice does not introduce a new Point-of-Sale (POS) fiscalization procedure.

What should retailers and software providers do now?

Businesses should review how incoming E-Invoices are checked before payment, establish responsibility for disputes, and ensure objections reach suppliers. Written explanations, supporting evidence, and correspondence should be retained together.

Where suppliers agree to corrections, accounting teams should verify the appropriate credit note or replacement invoice rather than simply deleting the original transaction record.

Software providers should test how internal rejection statuses differ from outbound messages and communicate this distinction clearly. A technical rejection should not be presented as automatic legal protection.

From a retail compliance perspective, the main risk is assuming that a software status completes the dispute process. Effective procedures should connect invoice data, delivery evidence, supplier communication, and accounting treatment. Questions concerning the legal effect of objections must still be assessed under Belgian law and the relevant contractual arrangements.

The main legal sources and supporting references are: Belgian Federal Government – E-Invoicing Requirements: https://einvoice.belgium.be/en/article/structured-electronic-invoices-between-companies-are-compulsory-2026, Belgian Federal Government – B2B E-Invoicing FAQ: https://einvoice.belgium.be/en/FAQ/general-questions-b2b, Belgian Civil Code – Article 8.11, Paragraph 4: , OpenPeppol – Peppol BIS Invoice Response 3.2: https://docs.peppol.eu/poacc/upgrade-3/profiles/63-invoiceresponse/.

Tara Nedeljković, Team Lead of Legal Consultants at Fiscal Solutions

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