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Belgium E-Invoicing & Digital Reporting Guide

E-InvoicingDigital Reporting

Belgium Electronic Invoicing and Digital Reporting Requirements

Current mandateUpcoming e-invoicing and e-reporting mandate
Indirect tax control regimePost auditCTC
E-Invoicing/CTC ModelB2G e-invoicingCTC (Continuous Transaction Controls) model for B2B from January 1, 2026.
Obligation statusPartially implemented with Phase II of B2G e-invoicing from May 2023Enacted, subject to the European Commision's approval.
Governing entityBelgian Tax Authority BOSABelgian Tax Authority BOSA
Infrastructure/platformMercurius (B2G) Hermes (B2B)Peppol model
Peppol connectivityYesYes
Current mandateUpcoming e-invoicing and e-reporting mandate
TaxpayersAll VAT-registered taxpayers supplying to the Belgian public sector.All taxpayers established in Belgium with certain exemptions
Domestic TransactionsB2G: Yes, B2B: VoluntaryB2B: Yes
Cross-border TransactionsVoluntaryVoluntary
DocumentsInvoices, Credit Notes, Message Level ResponseInvoices, Credit notes
Supplier-side requirements (AR)
Current MandateUpcoming e-invoicing and e-reporting mandate
Format(s) while sending to the platformPeppol BIS 3.0Peppol BIS 3.0
Format for exchange with buyer/recipientB2G: Peppol BIS 3.0, B2B: Any, to be agreed by trading partiesPeppol BIS 3.0
eSignature/SealNot requiredNot mandated
Buyer-side requirements (AP)
Current MandateUpcoming e-invoicing and e-reporting mandate
Receiving document in electronic formatMandatoryMandatory
Validation requiredOptionalMandatory
Acknowledgement of receiptOptionalTBD
Response to the document received (Accept or reject)OptionalTBD
Current MandateUpcoming e-invoicing and e-reporting mandate
Archiving AbroadAllowed with conditionsAllowed with conditions
Archiving Period7 years7 years
Other Digital Reporting Obligations
Current MandateUpcoming e-invoicing and e-reporting mandate
SAF-T or other accounting filingsNoNo

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The Belgian Government has introduced Business-to-Government (B2G) e-invoicing in phases. The timeline to implement the B2G e-invoicing mandate is as follows:

Implementation DateThreshold

Currently, e-invoicing is optional for business-to-business transactions (B2B); however, the introduction of mandatory B2B e-invoicing will start on January 1, 2026.

What Types of Businesses Does This Apply to?

Current mandate

Businesses selling to public entities. The mandatory e-invoicing for B2G transactions timeline is:

  • November 2022: e-invoices for public contracts over EUR 215,000 should be issued.
  • May 2023: e-invoices for public contracts greater than or equal to EUR 30,000 should be issued.
  • November 2023: e-invoices for public contracts below EUR 30,000 should be issued.

E-invoices for public contracts below EUR 3,000 are exempted from the B2G e-invoicing obligation.

Upcoming mandate

B2B e-invoicing is adopted and will go live from January 1, 2026. The supplier must be a VAT-taxable person established in Belgium (including a VAT group). There are exempted taxpayer groups:

  • A taxable person who exclusively carries out transactions exempted under article 44 of the Belgian VAT Code.
  • A taxable person applying the flat-rate scheme of article 56 of the Belgian VAT code
  • Taxable persons in a state of bankruptcy

Governmental Body Responsible for E-invoicing in Belgium

The Belgian Tax Authority (Federale Overheidsdienst Financien).

Penalties for Not Adhering to Belgium's E-invoice Mandates

In principle, the proportional penalties amount to 200% of the VAT (e.g. non-issuance of invoices or issue of incorrect invoices), and the non-proportional penalties generally amount to between EUR 50 and EUR 5,000 (e.g. non-compliance with the invoicing requirements).

What does the e-invoicing process in Belgium look like?

  • The Belgian government has adopted the ISO 20022 standard for its B2G e-invoicing system to make it compatible with other countries that have also adopted the standard.
  • Businesses are required to use e-invoicing software that is Peppol accredited.
  • The Belgium Peppol Authority (BOSA-DT) approves Peppol Access Point providers to provide entry and exit into the Peppol network. To send and receive compliant e-invoices in Belgium, businesses should connect to a Peppol Access Point. Peppol is an electronic data interchange (EDI) network that enables businesses to exchange documents electronically.
  • Businesses should maintain records of all invoices sent and received.
  • In order to ensure compliance with this regulation, Belgium organizes Access Point Providers' forums every 6 to 8 weeks.

More information on the B2B e-invoicing process will be published soon.

Is SAF-T Needed in Belgium?

SAF-T has not been introduced in Belgium.

Questions About E-Invoicing in Belgium?

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E-Invoicing & Global Tax Automation with Fonoa

One way to comply with Digital Reporting Requirements in Belgium is to use a provider like Fonoa.

With Fonoa you can:

  • Have one integration for your global needs, including Belgium
  • Save time and money by automatically cleaning your data to minimize errors and manual work
  • Utilize our validation mechanisms to ensure reporting accuracy, data completeness, full control, and compliance
  • Rest assured that transactions are successfully reported or queued for internal investigation with our retry mechanisms
  • Get full visibility with our dashboards by filtering criteria, analyzing granular transaction data, and quickly importing /exporting information

See how Fonoa can help

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