Peppol e-invoicing in Belgium: guide for foreign firms

What Belgium requires since 1 January 2026

Belgium made structured e-invoicing mandatory for domestic B2B transactions between two Belgian VAT-registered businesses from 1 January 2026. The legal basis is the Law of 6 February 2024, implemented by the Royal Decree of 8 July 2025.

A structured e-invoice is not a PDF. It is a data file that the customer’s software can read and post automatically. The default format is Peppol BIS Billing 3.0, which is based on the European standard EN 16931, and invoices travel over the Peppol network. Two parties may agree to use another EN 16931-compliant format, but every business in scope must remain able to send and receive via Peppol.

For an international group, this usually lands on the Belgian entity’s finance team and on whoever runs the group’s ERP or billing platform. A Dutch-owned logistics company with a warehouse in Antwerp, or a US software firm with a Brussels sales office, faces the same question: can the Belgian entity issue and receive Peppol invoices today, without manual workarounds?

The obligation runs in both directions. Your Belgian entity must issue structured invoices to its Belgian business customers, and it must be able to receive structured invoices from its Belgian suppliers, from the office landlord to the local IT contractor.

Does it apply to your Belgian set-up?

The verified core of the rule is narrow and clear: it covers domestic B2B invoices where both supplier and customer are Belgian VAT-registered businesses. How it applies to your group depends on how you are present in Belgium.

Published summaries differ on the edge cases, such as companies that hold a Belgian VAT number without a Belgian establishment, special VAT regimes, and invoices that cross borders. We do not repeat those lists here because they have not been confirmed against an official text. Confirm your position with a Belgian VAT adviser before assuming you are either in or out.

• Belgian subsidiary or branch invoicing Belgian business customers: treat Peppol issuing and receiving as mandatory.
• Belgian entity receiving invoices from Belgian suppliers: it must be reachable on Peppol.
• Belgian VAT registration without a Belgian establishment: get written confirmation of your status from a Belgian VAT adviser.
• Invoices between your Belgian entity and group companies or customers abroad: the 2026 rule is defined for domestic transactions, so confirm the treatment of cross-border flows with your adviser.
• Sales to consumers only: the rule targets B2B invoices, but your entity still buys from Belgian suppliers and should be able to receive.

Timeline: what has happened and what is next

Most of the key dates have already passed, so the obligation is fully in force. The table summarises the position as of October 2026.

Penalties and the VAT deduction risk

Fines escalate with repetition. According to the Royal Decree of 8 July 2025 and Article 70, paragraph 4, of the Belgian VAT Code, as summarised by several specialist firms, the amounts are EUR 1,500 for a first infringement, EUR 3,000 for a second and EUR 5,000 for the third and each later one.

The higher amounts apply when a further infringement occurs within three months of the previous one. An entity that issues invoices every week and keeps sending PDFs could reach the top tier quickly.

Connecting group systems to Peppol

Nobody connects to Peppol directly. You use an access point: a service provider that carries your invoices across the network to your customer’s access point and delivers your suppliers’ invoices to you. Many invoicing and accounting packages include one. Larger groups can instead connect their ERP to an access point provider through an integration.

Whatever route you choose, work through these questions with your finance and IT teams:

• Can your ERP or billing platform produce valid Peppol BIS Billing 3.0 invoices for the Belgian entity, or does it need a conversion step?
• Are inbound Peppol invoices posted into accounts payable automatically, or does someone re-key them?
• Does the access point contract cover every Belgian entity, and can it be extended to other countries later?
• If you use self-billing with Belgian partners, does your set-up support it now that the separate tolerance ended on 30 June 2026?
• Are customer master data correct, including Belgian VAT and enterprise numbers? A wrong identifier means the invoice does not reach the right recipient.
• Can you export invoices and switch provider without losing history?

The 120% deduction: check whether your entity qualifies

Belgium offers an increased cost deduction to help with the transition. According to UCM and Partena Professional, small companies and self-employed individuals can deduct 120% of the increase in cost caused by e-invoicing subscriptions, plus related consulting costs, for tax years 2024 to 2027. The software vendor must show the e-invoicing surcharge as a separate line on its invoice.

The measure is aimed at small businesses. Whether your Belgian entity qualifies depends on its size, so ask your Belgian accountant before budgeting for it. Do not confuse it with the digital investment deduction, which was raised to 20% from 1 January 2025. That is a separate measure with its own rules.

E-reporting from 2028: draft only

Belgium plans a second phase. A draft law provides for real-time e-reporting of invoice data to the tax administration from 2028. As of October 2026, it has not been enacted, so treat 2028 as provisional.

For planning purposes, the sensible move is to build the 2026 connection in a way that can be extended: clean master data, one system of record for Belgian invoices, and an access point provider that can support further reporting once the rules are final.

What to do now: a seven-step plan

If your Belgian entity is not yet fully compliant, or you are not sure, work through these steps in order.

1. Map your Belgian entities and how each is registered for VAT. Ask a Belgian VAT adviser to confirm in writing which of them are in scope.

2. Map invoice flows: outbound invoices to Belgian business customers, inbound invoices from Belgian suppliers, self-billing arrangements and intercompany invoices.

3. Test reception. Ask a Belgian supplier to send a Peppol invoice and confirm it arrives in your accounts payable process.

4. Choose or confirm the access point, and decide whether it is connected to your ERP directly or through your invoicing software.

5. Clean customer master data: Belgian VAT numbers and enterprise numbers for every Belgian business customer.

6. Automate the hand-offs. If invoices originate in a CRM, a subscription platform or an e-commerce system, connect it to the access point instead of exporting and re-uploading files. This is the kind of integration Synelo builds as a project.

7. Keep the 2028 e-reporting draft on your radar and review your set-up once the law is final.

This guide is general information as of October 2026, not legal or tax advice: check your situation with your Belgian tax adviser or FPS Finance.