Mandatory Structured Electronic Invoicing as of 2026

The Belgian government has postponed the introduction of the mandatory structured electronic invoicing to 1 January 2026. This implies that, as from 2026, Business-to-Business (B2B) transactions will have to be invoiced through a structured e-invoicing scheme.

Current Rules

B2B

To date, the use of electronic invoicing in Business-to-Business transactions is not mandatory in Belgium. However, it is highly recommended to companies to already align with the coming obligations.

B2G

Regarding Business to Government transactions, companies must electronically submit their invoices for public contracts exceeding €30.000,00. The requirement for public contracts valued between €3.000 and €30.000 will take effect on 1 March 1 2024.

In addition, B2G invoices are mandated to be transmitted via the "PEPPOL network" (Pan-European Public Procurement Online) and formatted as structured documents ("PEPPOL-BIS").

As from 2026: B2B Mandatory Structured e-Invoicing

As from 2026, all invoices and credit notes, issued by taxable persons established in Belgium to taxpayers registered for VAT in Belgium, must be generated in a structured electronic format facilitating automatic and electronic processing. The crucial requirement is the automatic and electronic processing without necessitating any manual intervention. This obligation will apply to both the issuer and the receiver of the invoice.

This obligation applies to all invoices (and corrective documents) issued between taxable persons (their respective Belgian VAT number needs to be mentioned on the invoice) for transactions taking place in Belgium with or without reverse charge mechanism, excluding VAT exempt transactions, according to the article 44 of the Belgian VAT code. However, the exception does not apply to any other VAT exemptions.

Issuer of the invoice

The requirement applies exclusively to companies and VAT groups based in Belgium. Consequently, foreign companies, registered for VAT purposes in Belgium, are exempt from the obligation to issue a structured electronic invoice, irrespective of whether they are individually identified or have designated a tax representative. However, foreign companies having a fixed establishment in Belgium will remain liable to issue structured electronic invoices their transactions.

In the case of internal transactions among members of the same VAT group, a "special document" must be issued if no regular invoice has been generated. Furthermore, these invoices or 'special documents' must also be issued in the format of a structured electronic invoice.

Finally, fully VAT exempt taxpayers (according to art. 44 of the Belgian VAT Code), bankrupt taxpayers or taxpayers who only carry out transactions subject to 0% VAT rate, are not concerned about this e-invoicing obligation.

Receiver of the invoice

Under the mandatory structured e-invoicing scheme, the customers hold an obligation to accept the invoice. This obligation will apply to all companies identified for VAT purposes in Belgium, including the foreign (non-established) companies, registered for VAT purposes in Belgium.

However, fully VAT exempt taxpayers (according to art. 44 of the Belgian VAT Code) are exempt from this obligation. 

Local transactions

The mandatory e-invoicing obligation is limited to : 

• Local Belgian transactions (not exempt from VAT according to article 44 of the Belgian VAT Code),
• Which are invoiced to a taxable person who is obliged to communicate its Belgian VAT identification number for these transactions. 

Note that for international transactions, the ViDa initiative foresees an entry into force of from 1 January 2028. 

Format of the e-invoices

The format of the e-invoices has not yet been defined,  but it is expected that the PEPPOL system will be imposed as main reference in this respect, as it is already the case for B2G invoicing.   In order to receive e-invoices, third parties can be used, such as the Hermes-platform.

If you have any questions regarding this topic, don’t hesitate to contact our RSM Belgium | Tax team ([email protected]).