Belgian B2B E-Invoicing – Changes and New Requirements

The Belgian coalition government has announced that starting from January 1, 2026, businesses conducting domestic B2B transactions will be required to issue electronic invoices. Furthermore, real-time reporting is planned to be implemented by 2028 to combat VAT fraud. Below is an overview of the key information regarding the upcoming changes and the next steps in implementing the new system.

New Obligations and Goals of E-Invoicing

As part of the efforts to counter tax fraud, Belgian regulations will require B2B invoices—including those generated by cash register systems—to be transmitted in real time to the tax administration. Cash register, payment, and invoicing systems will be integrated with the tax office, enabling immediate VAT data transmission.

Who and How Will Be Affected by the Obligation?

From January 1, 2026, all taxable entities operating in Belgium will need to issue electronic invoices for domestic B2B transactions subject to VAT. It’s important to note that these changes do not affect B2C transactions.The new regulations require the issuing, sending, and receiving of invoices in electronic form. As such, Belgium’s legal definition of an electronic invoice will now apply only to structured invoices, meaning those issued, sent, and received in a structured format that allows for automatic data processing. Simply sending a PDF by email will no longer be sufficient for the invoice to be recognized as electronic.

Full Implementation Without Phased Approach

Unlike other EU member states that are implementing gradual solutions, Belgium’s e-invoicing obligation will apply uniformly to all businesses, regardless of their size or industry. At this stage, digital reporting is not mandatory—the focus is primarily on the e-invoicing process, with real-time reporting scheduled for 2028.

Formal Approval at the European Level

The Belgian Parliament has approved the proposal to implement B2B e-invoicing, but the final implementation depends on approval from the European Commission. In September 2023, a request for authorization was submitted, which is necessary under current rules as member states must obtain a derogation from certain VAT Directive articles. Once the ViDA proposal is implemented, these restrictions will no longer apply, which may affect the final version of the regulations.

Scope and Format of the Obligation

The e-invoicing obligation applies to:

• Invoice Issuers: They must be registered taxpayers in Belgium. Certain groups, such as businesses engaged in exempt transactions or those in bankruptcy, are excluded.
• Invoice Recipients: They must be VAT-registered in Belgium or required to register for VAT in the country. Clients cannot refuse to accept electronic invoices.
• Transactions: These must be domestic and subject to Belgian VAT.

Additionally, starting March 1, 2024, e-invoicing will be mandatory for B2G (business-to-government) transactions, while B2C transactions remain exempt from these regulations. Notably, while the obligation mainly affects businesses operating in Belgium, all Belgian taxpayers will be required to accept electronic invoices.The standard format for electronic invoices is Peppol-BIS, though alternative solutions compatible with the European standard EN 16931 are allowed if the parties agree. PEPPOL (Pan-European Public Procurement On-line) plays a key role by ensuring interoperability and enabling cross-border e-invoice exchange between various countries and service providers.

The new Belgian e-invoicing regulations mark a significant step toward digitization and improving tax processes. Businesses will need to adjust their systems to comply with the requirements for issuing invoices in a specific, structured format, which will enable automatic data processing and enhance administrative control. Implementing these changes will contribute to greater transparency and more effective combatting of VAT fraud. Companies that adequately prepare will gain a competitive edge in the rapidly evolving digital environment.For official updates and further information on these changes, refer to government communications and additional informational materials.