E-invoicing as the new norm
On January 1, 2026, structured electronic invoicing will become the norm in Belgium for transactions between regulated companies.
The objective of electronic invoicing is twofold:
- On the one hand, to reduce the VAT gap, i.e., the difference between the VAT revenue the state should receive and what it actually collects;
- On the other hand, to pursue a deep administrative simplification for both taxpayers and the state.
The transition period offered to the concerned taxable person aims to ensure that everyone has the opportunity to adapt to this new invoicing method.
Starting from January 1, 2026, all transactions carried out in a B2B context (service provisions or goods deliveries between businesses) and subject to VAT in Belgium will fall under the new electronic invoicing method. In other words, this obligation will not apply to B2C transactions (operations between a business and an individual).
Notably, taxable persons exempt under Article 44 of the VAT Code, foreign taxable persons (even if they are VAT-registered in Belgium), or taxable persons in bankruptcy will not be required to issue electronic invoices.
The same applies when the client is an exempt taxable person (under Article 44 of the VAT Code). In this case, as with individual customers or non-VAT-registered customers, the supplier will not be subject to these new regulations.
Additionally, transactions classified as B2G (Business-to-Government) are already governed by specific European regulations in this area (since March 1, 2024).
But what does "electronic invoicing" mean?
The new definition of this concept was introduced by the European Commission’s ViDA proposal and adopted by Belgium. A structured electronic invoice is an “invoice that is issued, transmitted, and received in a structured electronic format that allows for automatic and electronic processing.”
As a result, invoices issued in PDF format are not considered structured electronic invoices!
The authenticity of the origin, the integrity of the content, and the readability of an invoice must always be ensured from the moment it is issued until the end of its retention period. The rules regarding this requirement remain unchanged.
Furthermore, a structured electronic invoice can be issued by:
- The supplier itself;
- A third party (in the name and on behalf of the supplier);
- The customer in the case of self-billing, if there is a prior agreement between the parties.
The PEPPOL network
To issue and receive electronic invoices, Belgium has chosen the PEPPOL BIS format, which defines the key elements of an invoice. It also recommends that electronic invoices be sent via the European PEPPOL network. “Pan-European Public Procurement On-Line” is an open network that enables taxable persons to send, receive, and process electronic invoices efficiently.
By joining this network, businesses and other organizations can easily and securely exchange invoices in a fast and efficient manner. The affected taxable persons can access the network through a single connection to a PEPPOL access point. This network is already in use in many member states.
However, taxpayers may, by mutual agreement, opt out of using the PEPPOL BIS format for invoices and choose an alternative system. In such cases, invoices must still comply with the European standard EN16931 to ensure harmonization.
Don't wait until it's too late
Electronic invoicing is driving businesses toward digital transformation. It is essential for companies to prepare as soon as possible for these changes.
That’s why it’s essential to begin this transition as soon as possible. Don’t wait until 2026, get ready now!
Our teams are at your disposal to answer any questions you may have on the subject, including legislative aspects, accounting tools and tax incentives.
