Who exactly is caught, and is a foreign group company in scope?
Who must issue
Taxable persons established in Belgium, for their B2B transactions whose place of supply is in Belgium.
Who must be able to receive
Every taxable person established in Belgium or holding a fixed establishment there — établissement stable in French, vaste inrichting in Dutch. A recipient cannot refuse a structured electronic invoice on the ground of its format; the receipt obligation is not something that can be negotiated away in a contract.
The exemptions
- taxable persons in bankruptcy;
- taxable persons carrying out exclusively transactions exempt under article 44 of the VAT Code — exempt from issuing and from receiving;
- taxable persons under the flat-rate regime (a regime itself due to disappear by 1 January 2028 at the latest);
- persons not established in Belgium who hold only a Belgian VAT number, without a fixed establishment;
- B2C transactions, which are outside the scope.
The word exclusively — exclusivement in the French text, uitsluitend in the Dutch — does all the work in the second exemption. A mixed taxable person, carrying out both article 44-exempt and taxed transactions, is not exempt. That is the most frequent misreading on this point, and it cuts both ways: a business that wrongly believes itself exempt neither issues compliant invoices nor is able to receive them.
For a group, the trigger is establishment, not registration. A group company registered for Belgian VAT — for distance sales, a call-off stock arrangement, or to recover input VAT — but with no fixed establishment in Belgium sits outside the obligation entirely. The moment it acquires a fixed establishment, it is inside, on both sides. That matters for where the question lives inside a group: it belongs in the fixed-establishment review, alongside permanent-establishment analysis, and not on the VAT registration checklist. The event that brings a group entity into scope is operational — a warehouse, an office, people — and operations will usually know about it months before tax does.
The receipt obligation catches entities that issue nothing. A Belgian entity whose only activity is purchasing has no invoices to send and is still required to be able to receive structured invoices. Groups routinely scope this project around the billing entities and discover the purchasing-only entities later, from a supplier who has already discharged his own obligation by sending to an address that does not resolve.
Is the administrative tolerance still running?
No. The FPS Finance — SPF Finances in French, FOD Financiën in Dutch — announced on 2 December 2025 a three-month tolerance covering 1 January to 31 March 2026. On 27 March 2026 it confirmed that the tolerance would not be extended. The obligation has applied in full since 1 April 2026.
A separate and narrower tolerance covered self-billing and ran until 30 June 2026. That has expired too.
A good deal of material still in circulation, in both languages, describes the tolerance as current. Any internal watch that rests on it has been five months out of date since the spring.
What are the fines?
Graduated administrative fines under article 70 §4 of the VAT Code:
| Infringement | Amount |
|---|---|
| First | EUR 1,500 |
| Second | EUR 3,000 |
| Subsequent | EUR 5,000 |
These come on top of the ordinary invoicing penalties; they do not replace them. A small note for anyone reading the two official texts side by side: the first figure is written 1 500 € in French and € 1.500 in Dutch. It is the same number, and the Dutch full stop is a thousands separator, not a decimal point.
How does the four-corner Peppol model work?
Belgium chose a Peppol four-corner model, with no central public platform for B2B and no clearance. The default format is Peppol BIS Billing 3.0 (UBL), which implements the European standard EN 16931.
Other formats or channels compliant with EN 16931 remain possible by mutual agreement between the parties — but every business must in any event remain technically able to receive via Peppol. Put plainly: you may agree something else with a given trading partner, but you cannot release yourself from the Peppol capability itself.
For the public sector the obligation is older: the law of 7 April 2019 and the royal decree of 9 March 2022, rolled out by contract value — from EUR 215,000 on 1 November 2022, from EUR 30,000 on 1 May 2023, and below that from 1 November 2023. Contracts under EUR 3,000 excluding VAT are excluded. The federal hub is Mercurius. At regional level, Flanders started on 1 January 2017, Brussels on 1 November 2020 and Wallonia on 1 January 2022 — dates worth knowing if a group entity has been selling to a regional authority for years and assumed that experience covers the new B2B rules. It does not: the B2G route through Mercurius is a different obligation from the B2B one.
The absence of clearance is the point a group used to Italy, Poland or Slovakia has to absorb. No authority validates the document, and no authority tells you it arrived. Whether an invoice reached its recipient is something you must be able to determine yourself.
What is coming in 2028, and what is its actual legal status?
The Council of Ministers approved on 18 July 2026, on the proposal of the Minister of Finance, an avant-projet de loi — a preliminary draft law, voorontwerp van wet in Dutch — introducing near-real-time VAT e-reporting from 1 January 2028. The announced elements:
- bilateral reporting — the supplier and the customer each report the same transaction;
- a reporting window of five days;
- transmission via Peppol using the ViDA Tax Data Document v1.0.0, moving Belgium to a five-corner model;
- abolition of the annual client listing for the businesses concerned;
- exclusion of transactions exempt under article 44.
Status: this is not a law. The text is awaiting the opinions of the Data Protection Authority — the APD in French, the GBA in Dutch — and of the Council of State (Conseil d'État / Raad van State). The law is expected in the autumn of 2026 and the implementing royal decree in early 2027. Any plan that treats the 2028 e-reporting as settled is planning against a text that has not been voted, and the elements above are announced intentions rather than enacted provisions.
That said, bilateral reporting is worth anticipating now, because it changes the nature of the risk rather than the volume of work. From the moment your customer reports the same transaction that you do, every divergence between the two becomes automatically visible. Discrepancies that the current system absorbs quietly would become signals.
Why does Belgium have two authentic texts, and when does that matter?
Belgium is a two-language market, and for a group this is more than a presentational detail. Federal legislation is enacted and published in the Moniteur belge / Belgisch Staatsblad in both French and Dutch, and both versions are authentic. Neither is a translation of the other. That is unusual — in most markets a group deals with, there is one official text and a courtesy translation — and it has three practical consequences.
There is no fallback version. Where the two wordings could be read differently, you cannot simply prefer the original, because there is no original. A term of art has to hold in both: assujetti / belastingplichtige, établissement stable / vaste inrichting, avant-projet de loi / voorontwerp van wet. Conversely, where the two read the same — as they do on the exemption's exclusivement / uitsluitend — the reading is settled and you can rely on it without further advice.
Administrative guidance is maintained as two separate publications. The FPS Finance publishes the same communications in French and in Dutch at different addresses, and they are updated as separate pages. A group watch list that monitors one language is monitoring half the source. Put both on the list, and do not assume that an unchanged page in one language means nothing has moved in the other.
Your own Belgian entity reads one of the two. Whichever language your local finance team works in is the version that reaches you when you ask them a question — and it will be the version their auditor and their adviser are quoting back to them. Where an answer from Brussels and an answer from Antwerp seem to differ, check whether you are looking at two readings or at two translations of the same reading.
What does a group finance function have to do differently?
Your Peppol registration decides where invoices land. If accounts payable are centralised in a shared service centre in another country, the Belgian entity's participant identifier still has to resolve to a route that reaches that centre. The obligation, however, remains with the Belgian entity and not with the service centre — so the entity has to be able to demonstrate receipt capability even where nobody in Belgium touches the document.
Monitor receipt as closely as issue. In most groups, outbound invoicing is instrumented and inbound is not. Here the exposure runs the other way, because a supplier who has sent correctly has discharged his obligation regardless of what happened at your end.
Do the exemption analysis per entity. The exclusivity test is applied to the taxable person, so a group with several Belgian entities can have one genuinely exempt entity and three that are not, and the exempt one is exempt from receiving as well.
Do not generalise Belgium across the region. Denmark, for instance, requires the bookkeeping system to be capable of sending and receiving via Nemhandel and Peppol BIS, but imposes no B2B exchange mandate at all: the Danish requirement is about the properties of the system, not the behaviour of the company. Same Peppol plumbing, entirely different legal object. A single compliance-calendar line reading e-invoicing: Denmark, Belgium will over-build in one and under-build in the other; the Danish position is set out under Denmark's digital bookkeeping rules.
What does this mean for automated processes?
Receipt capability is a single point of failure
You cannot refuse a structured invoice, and your Peppol registration determines where it arrives. If your access point is unavailable, invoices do not reach you — while the supplier has fulfilled his obligation. Monitor the processing status per document rather than only the availability of the connection: an access point that is up and a queue that is silently discarding documents look identical from a status page.
Resending after a failure creates duplicates
A timeout does not mean the invoice was not transmitted. Without an operation identifier assigned before the first attempt, a second attempt produces a second document. In a four-corner model, detection is slower than under clearance, because no central authority flags the duplicate — your customer does. A reliable control trail per operation, rather than per transmission, is the difference between a correction and an argument.
Preparing for 2028 is data quality now
Bilateral reporting would not forgive master-data discrepancies: VAT number, dates, amounts, references. What passes unnoticed today would be reconciled automatically. The useful work to start now is therefore not technical but qualitative, and it begins with master data and the references carried on the invoice rather than with a new format.
There is a governance tail to this for entities within the Belgian NIS2 law of 26 April 2024, in force since 18 October 2024, with supervision by the Centre for Cybersecurity Belgium. Where invoices are issued, checked and approved by systems — increasingly by AI agents — the management body must approve the measures for managing cyber risk, supervise their implementation and follow training itself, and the CCB may temporarily prohibit persons from exercising management functions at essential entities. The equivalent Danish provision, and what it means for setting approval thresholds in front of automated actions, is covered under approval thresholds for AI actions.
In practice
BarzelOps runs governed cross-system workflow automation with durable state, approval checkpoints and tenant isolation. Where invoice issue and receipt cross several systems and several entities, that is the layer the retry logic and the approvals sit in.
Frequently asked questions
Since when has the obligation applied?
Since 1 January 2026, with no phase-in by size and no threshold. The basis is the law of 6 February 2024 and article 53 §2 of the VAT Code.
Is a foreign group company with a Belgian VAT number in scope?
Not by virtue of the number alone. A person not established in Belgium holding only a Belgian VAT number, without a fixed establishment, is outside. Establishment is the trigger, not registration.
Is the tolerance still running?
No. It ended on 31 March 2026 and was not extended. The separate tolerance for self-billing expired on 30 June 2026.
Can we refuse a structured electronic invoice?
No. Receipt capability is mandatory for every taxable person established in Belgium or with a fixed establishment there, and cannot be refused on the ground of format.
Has the 2028 e-reporting been voted?
No. A preliminary draft — avant-projet / voorontwerp — was approved on 18 July 2026 and is awaiting the opinions of the Data Protection Authority and the Council of State.
Do we have to use Peppol?
You must be able to receive via Peppol. Another EN 16931-compliant channel remains possible by mutual agreement with a particular partner, but not instead of the Peppol capability.
Related reading
- Denmark's digital bookkeeping rules: a system requirement, not an e-invoicing mandate
- Approval thresholds for AI actions before execution
- AI audit trails: three requirements, not one
- Approval checkpoints in automated workflows
- AI agent governance: control before execution, evidence afterwards
- Glossary of European e-invoicing terms
- Corrections
In practice
The control has to run before the invoice becomes irreversible.
An accepted structured invoice can be corrected but never deleted, and from the penalty date every defect has a price. Barzel puts the approval threshold, the duplicate check and the signed record in front of submission, so the process can be defended on the day an auditor or the tax authority asks.
In forceB2B e-invoicing mandatory in Belgium since 1 January 2026
BarzelOps
Governed workflow automation across the systems that run the business.
- Durable, idempotent execution: a timeout is retried once, never filed twice.
- Human approval checkpoints that pause the workflow and resume it.
- Isolation per entity or client, signed evidence receipts and a portable manifest; HubSpot, Xero, Gmail, Google Drive and Slack.
Free tier: 100 calls a dayPaid plans from $19 a monthLive on MCPize
BarzelVault
The AI action firewall: decide what an agent may do before it does it.
- Approval thresholds and policy checks enforced before execution; human approvals that expire and escalate.
- Cryptographically signed audit receipts: trigger, inputs, policy version, approver, outcome.
- Credential isolation, spend and action limits, and an emergency kill switch.
Free tier: 10,000 calls a monthPaid plans from $199 a monthLive on MCPize
Enterprise: written quote by email within two business days. No sales call.
Sources
- Loi du 6 février 2024 / Wet van 6 februari 2024, Moniteur belge / Belgisch Staatsblad of 20 February 2024; article 53 §2 of the VAT Code. Left unlinked: the Justel consolidated pages carry generic titles and could not be tied to this instrument on verification.
- SPF Finances, mandatory use of structured electronic invoices from 2026; communications of 2 December 2025 and 27 March 2026 on the tolerance. The Dutch-language equivalent is published separately by FOD Financiën and is left unlinked here, the page having refused automated retrieval on verification.
- Council of Ministers, preliminary draft law on electronic reporting of invoice data, 18 July 2026.
- Loi du 7 avril 2019 and arrêté royal du 9 mars 2022 (B2G). Left unlinked for the same reason as item 1.
- European Commission, eInvoicing in Belgium.
- OpenPeppol, Peppol BIS Billing 3.0 — a Core Invoice Usage Specification of EN 16931.
- Centre for Cybersecurity Belgium, NIS2 — law of 26 April 2024.
This article is for information and does not constitute tax or legal advice. The French and Dutch texts of the instruments cited are both authentic and both binding. Position as at 3 September 2026.