Belgium’s 2026 B2B E-Invoicing Rules and Grace Period Explained

On December 3, 2025, the Belgian government published an updated Draft Law covering multiple VAT-related topics, including changes to the B2B e-invoicing mandate that will take effect on January 1, 2026. In addition, on the following day, the Belgian Tax Administration announced a three-month grace period for taxable persons to comply with the mandatory B2B e-invoicing requirement.

Key Amendments and Transition Period  

The published Draft Law once again reaffirms that mandatory B2B e-invoicing will start on January 1, 2026. The obligation to exchange e-invoices will apply to VAT-registered taxable persons. Notably, the Draft Law explicitly excludes non-Belgium VAT-registered buyers, removing any doubts or uncertainties for non-resident taxable persons. This is also critical for domestic taxable persons, who must verify the buyer’s establishment status to determine whether an e-invoice is required.

As noted by the Belgian Tax Administration, during the initial implementation of e-invoicing, practical issues may arise, and some businesses acting in good faith might not be able to meet all obligations due to circumstances beyond their control fully. Thus, the Administration will exercise tolerance during the first three months of 2026 and will not impose penalties for any breaches related to the new e-invoicing requirement, provided that taxable persons can demonstrate that they have taken timely and reasonable steps to comply.

Furthemore, the Draft Law provides a practical solution for cases where the recipient of an e-invoice cannot technically receive it. If, due to technical limitations, the recipient cannot receive or accept an e-invoice, the supplier is not required to issue one and may instead provide a valid invoice in paper or non-structured electronic form, such as a PDF or Word document. 

This provision protects suppliers who have made reasonable efforts to comply but encounter recipients who are not yet technically ready. However, this does not mean that the recipients are relieved from the obligation to be capable of receiving e-invoices, and may face sanctions if non-compliant. 

Conclusion

The updated Draft law and accompanying guidance from the Belgian Tax Administration reflect a balanced approach to the rollout of mandatory B2B e-invoicing. On the one hand, with the clarification provided, the government is demonstrating its determination to facilitate a smooth digital transition. 

On the other hand, by giving a three-month tolerance period and a fallback option for technical limitations, the Administration shows that it recognizes the operational realities businesses face and offers protection to suppliers acting in good faith.

Source: KPMG, Draft Law 1205/001, Federal Public Service Finance, VATabout