Mandatory electronic invoicing in Belgium from 01/01/2026 (proposal)

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Matthias Penninck
6 Oct 2023
Subject Tax alert
Categories Indirect Tax
Jurisdictions Belgium

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Recently, during the Council of Ministers, a preliminary draft law was approved on the introduction in Belgium of mandatory electronic invoicing for B2B transactions.

The preliminary draft still needs to be submitted to the Council of State for advice and also needs to be approved by the Belgian Parliament.

In addition, Belgium must request from the European Commission a derogation from the European VAT Directive. This preliminary draft forms the basis for the application for derogation to the European Commission.
 

What's changing?

The new proposal is characterised by two important changes:

  • There is no longer a phased entry into force from 1 July 2024, but there is now a general entry into force from 1 January 2026.
  • Mandatory electronic reporting will not be introduced together with electronic invoicing, but it is expected that this will take place at a later stage.
     

What are the key points?

  • The structured electronic invoice becomes mandatory. Peppol-BIS is introduced as the standard format, but by mutual agreement another format (within the European EN 16931 standard) can be used. A PDF format is no longer sufficient.
  • All taxpayers established in Belgium (subject to some specific exclusions) are obliged to issue them for local B2B transactions in Belgium.
  • The scheme does not apply to B2G or B2C transactions. A separate EU framework for electronic invoicing already exists for B2G.
     

How can you prepare?

Although the entry into force is foreseen on 1 January 2026, it is advisable to prepare and reflect on the business strategy to overcome this global trend in an integrated and structured manner.

At EY, we have extensive experience in assessing and rolling out international projects. We understand the complexity of such projects and understand that it can be challenging to comply with existing laws and regulations. That's why we have a team of dedicated experts who can help meet the requirements and/or participate in the implementation of the new system requirements.

Of course, we also stay informed of the latest developments and trends in the field of e-invoicing and reporting. Through our "Indirect Tax Development Dashboards" we have the perfect tool to closely monitor and display all global updates.

If you have any further questions, do not hesitate to contact us.