Background

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:

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 mandates

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

On 31 January 2025, Belgium's federal coalition government released the Federal Coalition Agreement 2025-2029, confirming the introduction of near real-time reporting from 2028. The e-reporting system will adopt a 5-corner Peppol model, enabling near-live transmission of invoice data to tax authorities.

Governmental Body Responsible for E-invoicing in Belgium

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.

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