Mandatory Structured E-Invoicing & Reporting Requirements in Belgium Key Information and Next Steps

We would like to inform you about the latest developments concerning the implementation of mandatory structured electronic invoicing (e-invoicing) rules and digital reporting in Belgium.

As you may already be aware, these new rules will affect all B2B transactions taking place in Belgium as of 1 January 2026. Furthermore, the planned Belgian and EU digital reporting obligations will gradually come into effect from 2028 (for Belgian domestic transactions) and from July 2030 (for intra-Community transactions).

All structured e-invoices will be transmitted over the secured PEPPOL network, using the PEPPOL-BIS standard. These changes will impact all your processes related to invoicing, accounts payable, and accounts receivable within your organization.

Summary of Key Changes and Next Steps

A.    Belgian Mandatory Structured B2B E-Invoicing

• Effective date: 1 January 2026
• Scope: Applies to all B2B transactions conducted in Belgium, affecting:

Outgoing invoices:

• Mandatory for all invoices and credit notes issued by taxable persons established in Belgium (including foreign entities with a fixed VAT establishment in Belgium) to other VAT-registered entities.
• Limited exceptions apply, such as for fully VAT-exempt taxpayers (per Article 44 of the Belgian VAT Code) and foreign companies not established in Belgium (without a Belgian fixed VAT establishment), etc.

Incoming invoices:

• All Belgian taxable persons, including foreign taxable persons with a fixed VAT establishment in Belgium, must be able to receive structured e-invoices.

No obligation exists for:

• VAT-registered taxpayers not established in Belgium (without a Belgian fixed VAT establishment)
• Fully VAT-exempt taxpayers without a right to deduct input VAT (Article 44 of the Belgian VAT Code)

B.    Near Real-Time Reporting

In addition to the e-invoicing obligation, the 2025–2029 Federal Coalition Agreement foresees the introduction of near real-time reporting for certain transactions in Belgium:

• Effective date: As of 2028
• Scope: B2B Transactions between VAT-registered entities and for transactions  involving registered cash systems.

Preparation is Key

Although detailed technical guidance from the Belgian government remains limited, the adoption of structured e-invoicing via the PEPPOL network and PEPPOL-BIS standard is confirmed. As implementation deadlines approach, we expect further clarification but early preparation is essential to ensure timely compliance and avoid business disruption.

Checklist – Key Questions to Assess Your Readiness:

• Internal expertise: Have you appointed a dedicated e-invoicing lead to oversee implementation?
• System capability: Is your invoicing or ERP system equipped to handle PEPPOL-BIS structured e-invoices?
• PEPPOL Access Point: Have you selected a software provider that can act as your Access Point for both inbound and outbound transactions?
• Integration tools: Do you require platforms such as Hermes for machine-to-machine invoice processing? Have you evaluated the associated costs?
• Process readiness: Have your internal procedures (e.g. invoice validation) been reviewed and updated accordingly?
• Transaction flow review: Have your supply and service flows (incoming/outgoing) been assessed for correct VAT treatment and timely VAT reporting—especially in light of the increased data cross-matching enabled by Belgian & EU digital reporting?
• Data integrity: Are your client/supplier databases, VAT codes, item/service price lists, and VAT numbers up to date to support accurate e-invoicing?
• Client & supplier communication: Are you prepared to inform your business partners to ensure a smooth transition and correct VAT deduction?
• Exception handling: Do you have clarity on which clients or transactions may be exempt?

Connecting to PEPPOL

To meet these new obligations, you may need to work with certified PEPPOL Access Points and service providers.

A full list is available [here]

* Software-oplossingen voor het verzenden, ontvangen en verwerken van elektronische facturen - e-factuur  
 (NL)    efactuur.belgium.be
* Solutions logicielles pour l'envoi, la réception et le traitement des factures électroniques - e-facture              
 (FR)    efacture.belgium.be

How RSM Belgium Can Support You

We are here to help you navigate these upcoming changes. Our experts can assist with:

• Readiness assessments
• Process reviews
• VAT analysis of your transaction flows
• Tailored implementation support

Should you have any questions or require further assistance, please do not hesitate to contact us.
We look forward to supporting you in successfully meeting these new regulatory requirements.