Belgium has stepped up its actions to enact legislation to support B2B e-invoicing. We can understand this from the approval of Bill No. 55K3743001 by the Chamber in January 2024.The legislation is currently available in Dutch and French and published in the Official Gazette on February 20, 2024. The law will require VAT-registered businesses in Belgium to send and receive structured electronic invoices using the Peppol network and Peppol-BIS standard from 2026.
Scope of the e-Invoice Regulation
Unstructured formats such as PDFs and paper invoices will no longer be allowed. To ease the transition, there will be a significant grace period. Although structured e-invoicing is already mandatory for invoices directed to the government, Minister Van Peteghem wants to make it the standard and to create a specific obligation within the framework of certain transactions between taxable persons (all B2B transactions) from January 1, 2026. However, the obligation to issue structured electronic invoices will also not apply to the supply of goods or services to natural persons for their private use (B2C or business-to-consumer transactions). The voluntary phase starts as of January 2025. Invoices issued must be issued in the PEPPOL-BIS format so that they meet European standards (in particular,it is an XML- UBL as defined in the ISO/IEC 19.845:2015 standard). Companies that currently use EDI for communication may continue to do so if both parties agree. Moreover, Belgium aims to align its e-reporting system with the European Union’s VAT in Digital Age – ViDA project to improve information exchange among Union countries.
Upcoming regulations in Belgium will apply to companies that are based in the country, local branches of foreign companies, and non-resident businesses that have both VAT registration and a Fixed Establishment, which includes premises and staff. The latest bill outlines a significant update, stating that non-resident customers may need to accept e-invoices from their resident Belgian suppliers for domestic transactions.
Structure of Belgian e-Invoicing System
Belgium has a two-stage approach as its preferred strategy for e-invoicing.
- The first stage involves implementing a PEPPOL-based structured e-invoicing system between taxpayers in a 4-corner model with no immediate government reporting required. However, alternative exchange platforms may be used by mutual agreement, as long as they comply with EU requirements.
- In the second stage, Continuous Transaction Control pre-clearance involving tax authorities will be added to create a 5-corner model which will encompass e-invoicing and near-real-time e-reporting to replace the annual customer listing report. The objective is to reduce the VAT Gap, which the EU estimates to be €4.8 billion annually in the latest assessment of Belgian VAT revenue against forecasts.
Belgium aims to align with the EU VAT in the Digital Age plans for a standardized e-invoicing system (EN 16931) across the EU, which will ensure interoperability. The Digital Reporting Requirement pillar outlines a planned mandatory structured e-invoicing mandate in the EU for intra-community supplies starting in 2030 or later. Currently, B2B e-invoicing is allowed without the obligation to generate a paper invoice, provided both parties confirm their agreement and sufficient secure controls are in place for the issuance, receipt, and storage processes.
Peppol and HERMES
The PEPPOL initiative provides, among other things, for the agreements regarding the formats and semantics of electronic invoices and the PEPPOL gateway makes it easier to exchange invoices in a correct manner. A connection via PEPPOL offers two major advantages . First of all, by joining once, you are automatically connected to all other participants in the network. Additional bilateral agreements are no longer necessary between participants.
HERMES on the other hand, acts as a link between companies that can automatically process structured electronic invoices and companies that are not yet equipped for this themselves. In other words, HERMES acts as a “failsafe” (or safety net) if the recipient is not yet known on the PEPPOL network, so that the sender is not technically unable to send his structured electronic invoice.
In concrete terms, HERMES converts every structured electronic invoice into a PDF version, taking into account the applicable European standard for electronic invoicing. The invoice is then sent to the recipient’s email address . In addition, HERMES enables recipients and senders of structured electronic invoices to track their delivery. HERMES allows you to send a structured electronic invoice to any company in Belgium. HERMES is designed as a temporary solution to avoid blocking the invoice sender as long as the invoice recipient is not yet known on the Peppol network.
How can SNI help you?
SNI offers an solution, which allows you to effortlessly produce invoices in the necessary format and seamlessly transmit them through service provider to recipients for the B2B transactions in Belgium. Within the solution, you can streamline the processes of creating invoices and converting them into desired files through automotion. SNI’s comprehensive solutions cover tasks such as data extraction, mapping, processing, and communication with the service provider, ensuring a seamless end-to-end e-invoicing experience.
