Belgium’s Bill 56K1846/001 proposes mandatory near-real-time electronic reporting of domestic B2B transactions through the Peppol network from 1 January 2028, introducing a five-day reporting deadline and abolishing annual customer listings for in-scope established businesses ahead of the EU’s ViDA requirements.
The Belgian government submitted Bill 56K1846/001 to the Chamber of Representatives on 27 October 2026, which amends Article 53quinquies of the Belgian VAT Code to introduce mandatory near real-time electronic reporting (e-reporting) for domestic B2B transactions starting 1 January 2028. The proposed start date is still subject to parliamentary approval.
This reform extends Belgium’s mandatory B2B structured e-invoicing framework (which took effect on 1 January 2026. It is designed to align with the European Union’s VAT in the Digital Age (ViDA) Directive requirements, taking effect on 1 July 2030, thereby preventing double IT transition costs for businesses and the tax administration.
Personal scope & edge cases
Belgium requires both suppliers and customers to electronically report in-scope domestic B2B transactions to FPS Finance, enabling near-real-time matching to detect discrepancies and prevent carousel fraud. Reportable documents include sales invoices, credit notes, corrective invoices and structured self-billing documents.
Non-established businesses holding a Belgian VAT number are exempt from mandatory reporting but may voluntarily opt in from 1 January 2028 to 30 June 2030, gaining an exemption from annual customer listings. Belgian-established suppliers selling to these businesses must still submit the structured invoice data to FPS Finance, even when no Peppol e-invoice is required.
VAT groups must report transactions individually through each member’s own sub-VAT number, covering both external transactions and internal supplies between members.
How reporting will work
- Peppol network standard: Reporting data must be transmitted through the secure Peppol network using e-invoicing software connected to Peppol access points. FPS Finance will not provide a separate reporting portal or dedicated API.
- Reporting deadlines: Submission deadlines will be set by Royal Decree, with a maximum of five calendar days after invoice issuance or receipt. Extensions may apply in cases of force majeure.
- Strict minimalist data scope: Reporting is limited to mandatory VAT invoice fields under existing Belgian VAT rules, in line with Privacy Authority recommendations.
- No de minimis threshold: All in-scope invoices must be reported regardless of value, as the EUR 250 exemption under Circular 3/1986 will not apply.
- Excluded transactions: B2C sales, Article 44 VAT-exempt healthcare, educational, financial and social supplies, and intra-Community supplies are excluded. Intra-Community supplies remain subject to existing reporting rules until the EU ViDA requirements take effect on 1 July 2030.
Transition & abolition of the annual customer listing
For Belgian-established taxpayers subject to e-reporting, transaction-based reporting permanently replaces the annual customer listing.
The final annual listing for 2027 transactions remains due by 31 March 2028, with no further annual filing required from 2028 onwards.
Non-established Belgian VAT holders that do not opt into e-reporting may continue filing annual customer listings for transactions through 30 June 2030, before the EU ViDA framework takes over on 1 July 2030.
