Belgium B2B e-Invoicing: Key Compliance Steps Under the Royal Decree for 2026

Belgium's Royal Decree published in the Belgian Official Journal on 14 July 2025 specifies the requirements for mandatory e-invoicing. This decree establishes mandatory e-invoicing for all B2B transactions starting 1 January 2026. The mandate aims to streamline invoicing processes, enhance compliance, and align Belgium with European standards. For businesses operating in Belgium, understanding and preparing for this e-invoicing mandate is essential. This article provides a comprehensive overview of the decree, including requirements, technical standards, penalties, and practical guidance for compliance.

What is the scope of Belgium’s B2B mandate?

The Royal Decree confirms that the e-invoicing mandate applies to all VAT-registered businesses in Belgium involved in B2B transactions. Domestic transactions between Belgian VAT numbers are fully in scope, whilst B2C transactions and cross-border invoices from or to non-Belgian VAT numbers are excluded. However, even for out-of-scope transactions, businesses may voluntarily issue electronic invoices provided the recipient agrees. All electronic invoices have to comply with the European standard EN 16931, ensuring semantic and syntactic consistency. Belgian businesses are required to possess the technical means to issue and receive e-invoices via the Peppol network, maintaining interoperability even if parties opt-out by mutually agreeing on an alternative transmission method. 

Which businesses are affected by the Royal Decree?

Belgian authorities have clarified that all established businesses that are registered for VAT in Belgium are subject to the e-invoicing mandate. This includes foreign businesses with a permanent establishment in Belgium. Certain exemptions apply, such as businesses operating under the flat-rate scheme or engaged in activities exempt under Article 44 of the Belgian VAT Code, which limits VAT deductions. Non-established suppliers providing services to Belgian VAT-registered entities are generally excluded from the mandatory requirement, though voluntary compliance is possible. Businesses can verify their obligations through the official e-invoice portal.

What are electronic invoices?

Electronic invoices are structured digital documents containing standardised data that enables automated processing by accounting systems and tax authorities. Unlike traditional PDF or paper invoices, e-invoices allow businesses to streamline reporting and reconciliation while ensuring accurate VAT calculations. Each invoice must include essential information such as supplier and customer VAT numbers, invoice date, invoice number, line-level details, total amount per VAT rate, and any applicable rounding. By following the syntax and semantic rules in UBL format, electronic invoices facilitate compliance with electronic invoicing requirements.

How does the Peppol network facilitate compliance in Belgium?

The Peppol network serves as Belgium’s default platform for transmitting electronic invoices. By using the Peppol BIS format in UBL version, businesses can securely issue and receive electronic invoices that comply with European standards, including semantic and syntactic rules defined by EN 16931. The network enables efficient, near real-time transmission between businesses, simplifying the exchange of structured invoices within Belgium’s B2B ecosystem. While the Royal Decree allows for alternative transmission methods by mutual agreement, businesses must possess the technical means to send and receive electronic invoices via Peppol. Integrating with the Peppol network ensures interoperability across Belgian businesses and aligns Belgium’s e-invoicing framework with broader EU initiatives, supporting standardisation and automated processing of invoices for VAT compliance.

Which technical standards are required for e-invoices?

Belgium’s mandate requires compliance with European semantic and syntactic standards. Structured electronic invoices must use the Peppol BIS format in UBL, in accordance with EN 16931. This ensures that electronic invoices contain all required fields in a consistent, machine-readable format. Businesses are also required to apply the new VAT rounding rules, which mandate rounding the total amount per VAT rate rather than per line. Companies must update ERP systems to generate and validate electronic invoices in the correct format, ensuring seamless compliance with the decree.

When do electronic invoices need to be issued and received?

Starting on 1 January 2026, all in-scope B2B transactions between VAT-registered businesses in Belgium must be invoiced electronically. The Royal Decree requires businesses to possess the technical means to issue and receive structured electronic invoices via the Peppol network, ensuring interoperability and compliance with European standards. While the decree does not mandate real-time clearance, Peppol facilitates efficient and timely transmission of e-invoices, supporting faster VAT reporting and reconciliation. Businesses are encouraged to prepare well in advance, ensuring that their ERP systems, staff, and internal processes can manage structured electronic invoices accurately. Proper implementation not only reduces the risk of non-compliance but also streamlines financial operations, enabling businesses to benefit from automated processing and improved accuracy in VAT calculations.

What penalties exist for non-compliance with mandatory e-invoicing in Belgium?

The Decree introduces new non-proportional penalties to enforce compliance. Failing to possess the technical means to issue and receive electronic invoices can result in fines starting at EUR 1 500 for the first infraction, EUR 3 000 for the second, and EUR 5 000 for subsequent violations. Additional proportional penalties, up to 100% of the VAT amount, may apply if invoices fail to meet essential requirements. Non-compliant invoices cannot be used for input VAT deduction, meaning businesses may face financial disadvantages in addition to administrative penalties. Timely compliance is therefore crucial to avoid financial and operational consequences.

How must electronic invoices be archived?

Archiving electronic invoices is a key component of compliance. Belgium’s rules require invoices to be stored in a manner that guarantees their authenticity, integrity, and readability for the statutory retention period. Electronic invoices must be accessible for audit purposes and verifiable by Belgian tax authorities. The decree permits digital archiving solutions, provided that structured electronic invoices are securely preserved and can be retrieved efficiently. Proper archiving practices ensure that businesses can substantiate their VAT claims and maintain compliance with regulatory requirements.

How will Belgium implement e-reporting in 2028?

. While the 2026 mandate focuses on B2B e-invoicing, the Belgian government plans to expand digital reporting obligations starting in January 2028. This future e-reporting initiative will require businesses to submit structured invoice data electronically to the Belgian tax authorities, improving transparency and facilitating accurate VAT compliance. Companies that implement structured electronic invoices in 2026 will be well-positioned to meet the upcoming e-reporting requirements, as their systems, workflows, and ERP integrations will already support standardised, machine-readable invoice data. Early preparation will be essential for businesses to adapt efficiently, ensure regulatory compliance, and minimise potential disruptions when the e-reporting mandate comes into effect.

What steps should businesses take to comply with e-invoicing in Belgium?

Businesses should start by evaluating their current invoicing processes to identify any gaps in technical capabilities. ERP and accounting systems must be updated to generate Peppol BIS e-invoices in UBL format, including all mandatory fields. Staff training and process adjustments are critical to ensure invoices are issued and received correctly. Collaboration between finance, IT, and third-party Peppol service providers is recommended to establish compliant workflows. Preparing in advance allows businesses to avoid penalties and maintain input VAT deductions. 

Ready to Comply with Belgium’s B2B E-Invoicing Mandate? 

Adapting to Belgium’s upcoming B2B e-invoicing requirements may seem complex, but eezi is here to make the transition seamless. As a registered Peppol Access Point, we provide e-invoicing solutions that ensure full compliance with the Royal Decree effective 1 January 2026. 

Every business has unique needs. eezi simplifies compliance, reduces administrative burden, and ensures your invoicing aligns with the Belgian e-invoicing mandate. Contact us today to implement a Peppol-compliant e-invoicing system that keeps your business ahead of regulatory changes and fully prepared for the future of digital invoicing in Belgium.