1. When does Belgium’s mandatory B2B e-invoicing obligation take effect?
Belgium’s mandatory B2B e-invoicing mandate will come into force on January 1, 2026. All VAT-registered businesses established in Belgium will be required to issue and receive structured electronic invoices for domestic B2B transactions. The mandate applies regardless of sector or company size, covering everyone from large corporations to sole proprietors, as long as they are VAT-liable and established in the country.
This mandate fully replaces traditional invoice formats such as paper or PDF files. Starting in 2026, PDF invoices will no longer be accepted for B2B transactions.
2. Which transactions are affected, and are there any exemptions?
The structured e-invoicing obligation in Belgium applies to all domestic B2B transactions between VAT-registered businesses that are permanently established in Belgium. This means that for any sale of goods or services between such entities, invoices must be issued and received in a structured digital format through the Peppol network.
However, there are several exemptions:
- B2C transactions are explicitly excluded from the mandate. Businesses selling directly to end consumers are not required to use structured e-invoices.
- VAT-exempt entities under Article 44 of the Belgian VAT Code (such as certain healthcare providers, educational institutions, and non-profits) are not obligated to send or receive structured invoices.
- Foreign businesses with a Belgian VAT registration but no fixed establishment in Belgium are also exempt from issuing e-invoices, though suppliers established in Belgium must still send them structured invoices.
- Businesses under a flat-rate VAT scheme (Article 56) are temporarily exempt until January 1, 2028.
3. What steps should businesses take now to get ready for the 2026 e-invoicing mandate?
Although the obligation only comes into force in January 2026, businesses are strongly encouraged to start preparing well in advance, as implementing an e-invoicing system involves both technical and operational adjustments.
Here are key steps companies should take:
- Assess current invoicing processes – Understand how your business currently issues and receives invoices and identify systems that will be affected.
- Contact your accounting or ERP software provider – Confirm whether your current solution supports structured e-invoicing and Peppol connectivity.
- Select a certified Peppol access point – Work with a service provider that can connect your business to the Peppol network. The Belgian government maintains an official list of certified providers to help businesses choose a compliant solution, and SNI is among them.
- Run internal tests and pilots – Begin exchanging test invoices to ensure everything works smoothly before the go-live date.
- Run internal tests, train staff, and update procedures – Start by testing invoice flows internally to identify potential issues and ensure your finance team is familiar with the new processes, legal requirements, and tools involved.
It’s also advisable to follow updates from the Federal Public Service Finance and consult the official communication toolkit, which offers practical guidance tailored to different types of businesses.
4. How will structured e-invoices be exchanged, and what role does the Peppol network play?
Structured e-invoices in Belgium will be exchanged exclusively through the Peppol network. Peppol (Pan-European Public Procurement Online) is not a platform, but a network of certified service providers, known as access points, that ensure secure and interoperable document exchange.
The system operates on a four-corner model:
- Corner 1: the sender
- Corner 2: the sender’s access point
- Corner 3: the receiver’s access point
- Corner 4: the receiver
Both sender and receiver choose their own access points, but because all access points follow the same standards (Peppol BIS Billing 3.0, based on EN 16931), invoices can be exchanged seamlessly. This model allows businesses to remain flexible in their software choices while guaranteeing compatibility.
Although there is no real-time tax clearance, Peppol access points perform validation checks (using schematrons) to ensure that the data meets both technical and legal requirements before delivering the invoice to the recipient.
5. What tools and platforms will support the transition to e-invoicing in Belgium?
To support the transition, Belgium provides a combination of infrastructure and informational resources. The key platforms are:
- Mercurius: A federal “mailroom” platform that facilitates the exchange of e-invoices for public sector entities. It allows integration with Peppol and offers a web portal for manual invoice submission and tracking.
- Hermes: A transitional tool for recipients who are not yet able to process structured invoices. Hermes converts structured invoices into readable PDFs, ensuring inclusiveness during the transition phase.
In addition, the official communication toolkit released by the Federal Public Service Finance organization provides essential resources to help businesses prepare. These include:
- Clear explanations of the legal obligation
- Step-by-step onboarding advice
- Sector-specific guidance
- Promotional materials for raising awareness among stakeholders
By combining regulatory clarity, technical infrastructure, and financial support, Belgium aims to ensure a smooth and inclusive rollout of the e-invoicing mandate.
