Belgium: Guidelines For Mandatory B2B e-Invoicing Issued

July 18, 2024

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Belgium: Guidelines For Mandatory B2B e-Invoicing Issued

In February of this year, the Belgian Parliament approved and published the Law amending the Value Added Tax Code and the Income Tax, implementing mandatory domestic business-to-business (B2B) e-invoicing in Belgium as of 1 January 2026.

The Belgium Federal Public Service Finance (FPBF) published guidelines clarifying key elements as part of the implementation process of B2B e-invoicing.

Key Details of the Guidelines

The FPBF guidelines are divided into several areas in the following structure:

What is an electronic invoice?
Mandatory use of structured electronic invoices from 2026
International Billing (cross-border transactions)
Technical rules for an electronic invoice
Summary of invoicing within Belgium from 1 January 2026
More information

These guidelines provide key details such as the invoice format, scope of e-invoicing, and e-invoice exchange methods.

According to the guidelines, structured e-invoices must comply with EN16391 and European Standard, meaning that they must be able to be drawn up in the Peppol BIS format. In addition, the guidelines state that PDF invoices will remain valid for B2B transactions until December 31, 2025. For all other transactions, such as B2C or international, including cross-border, invoices in PDF format will remain valid after January 1, 2026.

Regarding the scope of e-invoicing, the obligation applies to transactions between Belgium VAT-registered businesses, except those that are specifically exempt. These exemptions include bankrupt VAT taxpayers and those not established in Belgium without a permanent establishment.

Guidelines provide information on cross-border transactions. Still, they also note that rules might change depending on the outcome of adopting and implementing the VAT in the Digital Age (ViDA) package.

Part of the guidelines also covers the technical rules for e-invoices, explaining what terms the authenticity of the origin, the integrity of the content, and the legibility of an invoice mean, and that they must always be guaranteed.

The FPBF also provided a list of existing e-invoicing legislation to help businesses transition to mandatory B2B e-invoicing.

Conclusion

The implementation of mandatory B2B e-invoicing is in line with the ongoing changes on the EU level concerning the ViDA proposal, which aims to introduce an EU-wide e-invoicing mandate and e-reporting obligations for cross-border transactions.

Source: Belgian Federal Public Service Finance, Law amending the Value Added Tax Code and the Income Tax Code

What is the timeline for implementing mandatory B2B e-invoicing in Belgium?

Belgium will mandate structured electronic invoicing for domestic business-to-business (B2B) transactions starting January 1, 2026. This requirement applies to nearly all transactions between Belgian enterprises liable to VAT.

Which transactions are subject to the mandatory e-invoicing requirement?

The obligation encompasses transactions between Belgian VAT-registered businesses, excluding specific exemptions such as bankrupt VAT taxpayers and foreign entities without a permanent establishment in Belgium.

What are the technical specifications for compliant e-invoices?

The technical specifications state that structured e-invoices must adhere to the European Standard EN16931, a standard for e-invoicing in Europe. They must also use the Peppol BIS (Business Interoperability Specifications) format, which is designed for secure and interoperable exchange of e-documents across different systems. The Peppol network ensures a standardized and secure mechanism for the exchange of compliant electronic invoices.

Will PDF invoices remain valid under the new regulations?

PDF inble for B2B transactions until December 31, 2025. Starting January 1, 2026, only structured electronic invoices will be valid for domestic B2B transactions. However, for business-to-consumer (B2C) and international transactions, including cross-border dealings, PDF invoices will continue to be valid beyond this date.

How should businesses prepare for the transition to mandatory e-invoicing?

Businesses should first assess their existing invoicing systems to determine whether they can accommodate structured electronic invoicing. They must collaborate with IT and accounting professionals to adopt software solutions that comply with the Peppol BIS format and other technical specifications outlined by the European Standard EN16931. Training staff on the processes of creating, sending, and managing structured electronic invoices is critical. Additionally, businesses should begin transitioning before the January 1, 2026, deadline to avoid disruptions.

Are there any exceptions to the mandatory e-invoicing requirement?

Yes, certain entities are exempt, including bankrupt VAT taxpayers and foreign businesses without a permanent establishment in Belgium. Additionally, the obligation does not apply to supplies of goods or services provided to individuals for their private use (B2C transactions).

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