Belgium's shift to mandatory electronic invoicing raises a host of practical questions: which documents must be sent electronically, how to handle credit notes, VAT categories, reverse charge clauses, and multiple orders, and whether simplified or summary invoices are still allowed. There are also important implications for VAT deduction rights and legally required company information. And with new penalties of up to EUR 5,000 per offence introduced in July 2025, the cost of not being ready is rising fast.
Belgium’s tax authorities have updated the FAQs about e-invoicing. As of July 2025, Belgian businesses are required to send and receive invoices electronically.
This follows the announcement by Belgium’s Federal Public Service (SPF) Finance on 2 April 2026 that the three-month grace period for mandatory electronic invoicing, which began on 1 January 2026, had ended. As a result, all VAT-registered businesses in the country are now required to comply with structured e-invoicing requirements.
Below are the key takeaways:
The Peppol network
Peppol is the official digital network used to send and receive electronic invoices in Belgium. Businesses that want to become Peppol service providers can find all the information they need on the national authority’s website, operated by FPS BOSA.
When new versions of Peppol are released, service providers must respect a transition period before enforcing the new format on their customers. Violations can be reported to the Belgian Peppol authority by email.
Peppol cannot automatically detect whether an invoice is a duplicate. It is therefore the responsibility of businesses and their accounting software to flag and prevent the same invoice from being recorded or declared twice.
Sending an invoice to a third party — such as a public authority payment system — currently still needs to be done manually outside of Peppol, though automation is being developed for the future.
What documents must be sent electronically
The e-invoicing obligation does not just apply to standard invoices. Credit notes and debit notes that refer to an original electronic invoice must also be sent through the same electronic channel and in the same format as the original.
If the original invoice was not issued electronically — for example, it was sent as a PDF — then there is no requirement for the credit note to be electronic either.
Summary invoices and simplified invoices are still allowed under the new rules and must also be sent electronically.
Self-billing — where the customer issues the invoice on behalf of the supplier — is supported, but requires the supplier to register on the network to receive those documents, and a prior agreement between both parties is always required.
VAT and Tax categories
A single invoice can include goods or services that fall under different VAT categories — for example, some lines at the standard rate and others that are exempt. This is permitted.
However, mixing transactions that are completely outside the scope of VAT with those that are subject to VAT (even if exempt) on the same invoice is technically not allowed under the current European rules. As a temporary workaround, businesses can use a free text field on the invoice to clarify the situation until the European rules are updated.
Similarly, if multiple lines on the same invoice are VAT-exempt but for different reasons, the current rules technically require separate invoices. As a temporary measure, the different reasons can be explained in the notes on each line of the invoice.
If a specific VAT exemption reason is not found in the official list, it can be written out in plain text in the exemption notes field on the invoice.
Reverse charge and other VAT clauses
When the reverse charge mechanism applies — meaning the buyer rather than the seller is responsible for paying the VAT — this must be clearly stated on the invoice, along with the required legal references. This can be written as a general note on the invoice or as a note on the relevant line.
If an invoice mentions “reverse charge” but is missing some of the required legal details, the recipient does not need to reject it. The supplier simply bears the risk that the legal protection normally offered by that clause may not apply. The recipient can still process the invoice and apply the reverse charge accordingly.
Practical invoice situations
Multiple orders on one invoice: The current rules require a separate invoice per order. A temporary solution has been developed while the European standard is being updated.
- Foreign currencies: Invoices can be issued in foreign currencies, but the total VAT amount must always be stated in euros.
- Date of delivery or service: If the date the goods were delivered or the service was performed is different from the invoice date, this must be stated somewhere on the invoice.
- Multiple languages: There is currently no official way to include product names or descriptions in more than one language on the same invoice. This is being discussed at the European level.
Specific legal and company information
Certain information required by Belgian company law — such as the legal form of the business, its registration in the register of legal entities, or whether it is “in liquidation” — should be included in the designated company information section of the invoice.
If the buyer has a tax representative, their details can be included in the general notes section of the invoice, as there is no dedicated field for this in the standard.
The right to deduct VAT
For a business to claim a VAT deduction on an incoming invoice, it must hold a valid and compliant invoice. Once the electronic invoicing obligation applies to a transaction, this means the business must have a structured electronic invoice to support its deduction claim.
There is an exception: if all the underlying conditions for the deduction are genuinely met, the tax authorities will not automatically deny the deduction simply because the invoice format is wrong. However, businesses without the technical means to receive electronic invoices may still face administrative fines.
Invoices received from private suppliers — such as utility bills for gas, electricity, or water — are not covered by the electronic invoicing obligation. Businesses can still declare a portion of these as professional expenses based on the paper or PDF invoice they receive.
Wrong recipient situations
If you receive an invoice not meant for you, you should reject it. It cannot be used for VAT deduction and, according to accounting standards, should not be entered into your accounts. You may contact the supplier to inform them of the error.
If you send an invoice to the wrong recipient, the invoice still needs to be recorded in your outgoing invoice records and included in your VAT return. You must then issue a credit note to cancel the incorrect invoice. This applies regardless of whether invoicing is paper-based or electronic.
Transactions exempt from the e-invoicing obligation
Certain specific transactions — such as property disposals and first occupations of buildings — have never required a standard invoice under Belgian VAT law. Because there was no invoicing obligation to begin with, there is also no electronic invoicing obligation for these transactions. A separate legal document is still required, but it does not need to be an electronic invoice.
Sanctions for non-compliance
Businesses that do not comply with the electronic invoicing rules can face financial penalties. These cover situations such as:
- Failing to issue an electronic invoice at all, or issuing one with missing or incorrect information.
- Not issuing the invoice within the required timeframe.
- Not complying with the technical requirements for electronic invoices.
A new penalty introduced in July 2025 specifically targets businesses that do not have the technical means to send or receive electronic invoices. The fines are EUR 1,500 for a first offence, EUR 3,000 for a second, and EUR 5,000 for each subsequent offence.
The evolving European standard
Many of the current limitations and workarounds described above exist because the underlying European invoicing standard is still being updated. A revised version is in progress and is expected to resolve issues such as combining different VAT categories on one invoice, handling multiple orders, and supporting multiple languages.
In the meantime, the Business Expert Group on E-Invoicing (BEG) — a Belgian working group — has developed practical interim solutions and published detailed examples to help businesses navigate the current rules.
