Starting on 1 January 2026, Belgium will implement mandatory structured electronic invoicing for most B2B transactions between Belgian established and VAT-registered businesses. Today, a Royal Decree was published formalising that Peppol will be the default method for issuing invoices.
In detail
The most important items included in the Royal Decree are the following:
- For transactions within the scope of the e-invoicing mandate, structured electronic invoices must, in principle, be issued in compliance with the European semantic and syntax norms related to electronic invoicing, as concretised in the Peppol BIS format in the UBL version and exchanged via the Peppol network.
- Opt-out from Peppol is possible, provided there is an agreement between the parties and to the extent that a structured electronic invoice is issued that complies with the European norm related to electronic invoices and its list of syntaxes. A taxpayer may use formats other than those complying with the European standard, but only to the extent that they are converted into one of the formats complying with the European standard before proceeding with the issuance of the invoice.
- All taxable persons who are in the scope of the mandatory e-invoicing obligation need to possess the technical means to issue and receive structured electronic invoices via Peppol. This requirement applies even when they rely on the opt-out possibility.
- A new non-proportional penalty will be introduced of EUR 1.500 (first infraction), EUR 3.000 (second infraction) or EUR 5.000 (from the third infraction) for not having the technical means that enable the issuance and receipt of structured electronic invoices via Peppol. To give the taxpayer some time to take action, a second or subsequent infraction can only be established at the earliest three months after the previous infraction that led to a penalty. Existing proportional and non-proportional penalties related to invoices can also be applicable to structured electronic invoices.
- For structured electronic invoices issued in accordance with the European semantic and syntactic standards, rounding will only be possible for the total tax amount included on those invoices, and not per line (per transaction) of the structured electronic invoice.
Impact and what’s next
With the publication of the Royal Decree, the Belgian authorities continue preparations for the big bang rollout of the B2B e-invoicing mandate on 1 January 2026. As expected, the Royal Decree offers little additional information regarding the implementation of the mandatory e-invoicing obligation. However, it is clear that all businesses within the scope of the e-invoicing mandate will need to be able to connect to the Peppol network, even if they intend to rely on the opt-out possibility.
Over the next few months, people, processes, and technology will need to adapt to ensure compliance with the mandate. In this regard, it will be crucial for companies preparing for the upcoming B2B e-invoicing changes to take the near real-time reporting obligation starting in 2028 into account when defining their strategy, selecting technology, and reviewing the impact on data availability and accuracy.
E-invoicing (and e-reporting) are not merely IT integration or finance automation projects, they are strategic compliance initiatives that directly impact tax exposure and operational efficiency. If you need help understanding the impact of these changes on your business or require an independent expert perspective on your plan to meet this obligation, we are ready to support you in achieving compliance and operational readiness. Our experienced team is ready to offer trusted insights and guidance, enabling you to navigate the upcoming mandate with confidence and peace of mind.
For more insights, please do not hesitate to reach out to Ellen Cortvriend, Sven Geenens, Brecht Van Petegem, or your regular PwC contact.
