Hanuma Global
Services Consulting & Training Resources Insights & articles Country mandate tracker Readiness scorecard Company About us How we work Helios ↗ Contact us

E-invoicing in Belgium

Live Confidence: high Checked 21 Jul 2026
ModelPeppol · 4-corner (moving to 5-corner in 2028)
Required formatPeppol BIS Billing 3.0 (EN 16931)
TimelineSince 2026

Who is in scope

Domestic B2B between Belgian VAT-registered taxable persons, including Belgian fixed establishments of foreign entities and members of Belgian VAT groups. Out of scope for ISSUING: entities that are only VAT-registered in Belgium without an establishment, taxpayers performing solely VAT-exempt (Art. 44) activities, taxpayers in bankruptcy, and (until 2028) the flat-rate scheme. B2C is out of scope, but a supplier still has to be able to RECEIVE e-invoices from its business suppliers. Intra-community supplies and services taxed elsewhere in the EU are excluded.

Key dates

  • 20 Feb 2024 Law amending the VAT Code published in the Belgian Official Gazette, establishing the B2B mandate.
  • 1 Jan 2026 Structured e-invoicing mandatory for all VAT-liable transactions between Belgian VAT-registered businesses, sent over the Peppol network in Peppol BIS 3.0. Paper and PDF no longer acceptable.
  • 1 Jan 2026 → 31 Mar 2026 Three-month tolerance period announced by FPS Finance — no sanctions for infringements directly linked to the new obligation, provided the taxpayer can show reasonable and timely efforts to comply (assessed case by case).
  • 1 Apr 2026 Progressive penalty regime in force under Royal Decree No. 44: €1,500 for a first infringement (lacking the technical means to issue/receive), €3,000 for a second, €5,000 thereafter, with a three-month buffer between findings.
  • 1 Jan 2028 Near-real-time e-reporting of invoice data to FPS Finance — Peppol 5-corner model — expected to replace the annual client listing. Flat-rate scheme exemption also falls away.
What practitioners get burned by

The exclusions are the burn risk: a foreign group that is only VAT-registered in Belgium (no fixed establishment) is NOT obliged to issue Belgian e-invoices, and plenty of vendors told such clients otherwise. Conversely, a Belgian fixed establishment of a foreign entity IS in scope. Second, the tolerance period was conditional, not blanket — FPS Finance said it only protects taxpayers who can evidence reasonable and timely efforts, and it is over regardless. Third, do not treat 2026 as the finish line: the 2028 e-reporting layer converts Belgium from 4-corner exchange into a 5-corner CTC regime and retires the annual client listing.

Sources

4 of 7 are primary sources. Mandate dates move — treat this page as a starting point and confirm against the primary source before committing a plan.

Also in Europe

Planning for Belgium?

A page is a starting point. A scoped analysis gives you the specification, the mapping and the effort — in weeks, not quarters.