Belgian e-invoicing regulations as per 1 January 2026 - be ready!

Starting 1 January 2026, Belgium will implement mandatory structured electronic invoicing (e-invoicing) for B2B transactions, with EU digital reporting requirements to follow shortly thereafter. These changes will significantly impact your invoicing processes.

Effective Start Date

1 January 2026

Scope

Applicable to all B2B transactions taking place in Belgium, impacting:

• Your issued invoices (Accounts receivable):
  • This obligation applies to all invoices and credit notes issued by taxable persons established in Belgium to other VAT-registered taxpayers for supplies located in Belgium.
  • Only limited exceptions exist, such as:
    •  Fully VAT-exempt taxpayers (per Art. 44 of the Belgian VAT Code).
    • Foreign companies without a fixed establishment in Belgium.
• Your receipt of invoices (Accounts Payable) by:
  • Belgian VAT taxable persons.
  • Non-established taxable persons registered for VAT in Belgium for local transactions (not yet for intra-Community acquisitions).
  • While foreign taxable persons are not required to issue e-invoices under Belgian e-invoicing regulations, they must be capable of receiving e-invoices in Belgium.

Support measures

Two supportive tax measures are provided for SMEs and self-employed individuals:

• From January 1, 2025: the investment deduction for digital investments will increase to 20%;
• Increased expense deduction (120%): small SMEs and self-employed individuals who use subscription models will apply an increased expense deduction of 120% for invoicing software (provided the additional cost is separately mentioned on the invoice).

Preparation is key

While detailed guidance from a Belgian perspective remains limited, the transition to structured e-invoicing is certain. As the introduction date approaches, we expect further clarity, but early preparation is essential to ensure compliance and avoid disruptions.

Checklist to help you prepare

To support your company, here is a checklist of key considerations:

• In-house specialist:
  Have you appointed a dedicated in-house e-invoicing specialist to oversee the implementation and readiness within your organization?
• System readiness:
  Is your current invoicing or ERP system capable of generating and processing structured e-invoices in the PEPPOL-BIS format?
• Software suppliers:
  Have you identified a software supplier or PEPPOL Access Point provider to assist with your incoming and outgoing transactions?
• Software integration:
  Do you need additional tools or platforms (e.g. Hermes) for machine-to-machine handling of e-invoices? If so, have you assessed the associated costs?
• Internal process review:
  Have you reviewed and updated your internal processes (e.g. invoice validation) to align with electronic invoicing requirements?
• Transaction flows:
  Have you analyzed your incoming and outgoing transaction flows (supply of goods and services) to ensure accurate VAT treatment and timely reporting?
• Data accuracy:
  Have you ensured the completeness and accuracy of client and supplier databases, tax codes, price lists, VAT identification numbers, etc., to populate your structured e-invoices correctly?
• Client/supplier communication:
  Are you prepared to inform your clients and partners about the transition to structured e-invoicing to ensure smooth adoption and correct VAT deduction on their end?
• Exception management:
  Are you aware of which transactions or clients may be exempt from these requirements?
• VAT review process:
  Have you implemented a robust VAT review process to ensure compliance with Belgian VAT regulations and the accuracy of VAT reporting under the new e-invoicing requirements?
• VAT compliance:
  Are your compliance procedures up to date to meet the increased scrutiny from tax authorities, including timely VAT returns and adherence to EU digital reporting standards?

Resources for PEPPOL Access Points and service providers

To facilitate this transition, you may need to connect with certified PEPPOL Access Points and service providers. A comprehensive list of software providers is available [here].

How RSM Belgium can assist you

At RSM Belgium, we are here to help you navigate these significant changes. Our teams can assist with:

• Readiness assessments.
• Process reviews.
• VAT analysis of your accounts payable and accounts receivable.
• Implementing tailored solutions to meet your business needs.
• Reviewing your VAT processes and ensuring compliance with the new regulations.

If you would like to receive additional information on this matter or require VAT assistance, the RSM Belgium Tax team is at your disposal [email protected]).