Belgium's government submitted a draft law to Parliament on October 27, 2026 introducing mandatory near-real-time electronic reporting of invoice data. The proposal would require affected businesses to transmit specified invoice data to the Belgian tax authorities, building on the country's existing B2B e-invoicing mandate. The new reporting obligation would also replace the annual client listing for businesses within its scope.
Belgium's proposed e-reporting implementation timeline
The proposed e-reporting requirements would take effect on January 1, 2028, subject to parliamentary approval. The final annual client listing covering transactions in 2027 would remain due by March 31, 2028 for businesses currently required to submit it.
What Belgium's proposed e-reporting requirements mean for businesses
The proposed legislation would amend Article 53quinquies of the Belgian VAT Code, introducing transaction-level reporting linked primarily to the structured electronic invoicing requirements in force since January 1, 2026.
Key provisions include:
- Bilateral reporting: Both suppliers and customers would be required to report specified data from structured electronic invoices they issue and receive. Certain equivalent electronic documents and subsequent corrective documents would also be covered.
- Extended scope: Belgian-established suppliers would be required to report covered domestic transactions involving customers registered for VAT in Belgium but not established there, even where issuing a structured electronic invoice is not mandatory. These non-established customers would not themselves be subject to mandatory e-reporting.
- Reporting timeframe: Invoice data would be transmitted through the Peppol network within a maximum of five calendar days, with exceptions for force majeure circumstances as defined by the authorities. The precise reporting deadlines and technical requirements would be specified in a future Royal Decree.
- Data requirements: Reporting would reflect invoices as originally issued and received, before internal business validation. The reportable data fields would be determined by Royal Decree and limited to information required under VAT invoicing rules.
- Annual client listing: The existing annual client listing would be abolished for taxpayers subject to mandatory e-reporting. The current administrative tolerance allowing certain invoices with a taxable amount of €250 or less to be omitted would not apply under the new reporting regime.
For affected businesses, the proposal introduces an additional reporting layer alongside existing e-invoicing obligations. Businesses should assess their Peppol connectivity, ERP and invoicing workflows, invoice data quality, and correction processes to prepare for timely and accurate reporting once the legislation and implementing requirements are finalised.
