Belgium’s Business-to-Business (B2B) e-invoicing mandate has been approved within Belgium’s domestic legislative framework and will take effect from 1 January 2026.

Since its ratification, the Belgian Federal Public Service Finance has provided limited information concerning what the e-invoicing community can expect once the mandate is implemented. The Belgian government has now published a set of guidelines which provide a clearer indication of the trajectory of the upcoming e-invoicing mandate.

Much of the information released is in line with earlier communication circulated by the Belgian government. By means of some key points:

• The Belgian government has re-affirmed that structured invoices only must be exchanged between suppliers and buyers from 1 January 2026 which conform to the European e-invoicing standard, EN16931.
• As expected, Peppol is expected to feature heavily as part of Belgian’s e-invoicing infrastructure, with a certified service provider required to facilitate invoice exchange via Peppol. Invoices must conform to the Peppol-BIS standard. Currently, invoices do not need to be reported to tax authorities, in line with the Peppol 4-corner model. A 5-corner model, which integrates tax authorities as part of its framework, may form part of Belgian’s broader e-invoicing vision at a later stage.
• The regulations also confirm the scope of Belgium’s e-invoicing obligations, with significant differences for both invoice issuers and receivers:
  • Invoice issuers: Belgium entities who are established, VAT-registered entities come under scope of Belgium’s e-invoicing obligations
  • Invoice receivers: Belgium’s entities who are VAT registered only must also comply with upcoming e-invoicing obligations from 1 January 2026 in addition to established entities, indicating a much wider scope for invoice receivers.

In a similar vein to the Polish Government, the Belgian government is offering tax incentives to offset some of the expected costs associated with compliance with the new regulations.

Belgium’s e-invoicing mandate plans have already been published in the Gazette in February 2024 and enshrined in the country’s national legislation. However, it still requires approval from the European Commission to proceed by way of a derogation. This appears to be a formality only.

The guidelines can be accessed here.

Tungsten Automation is already a Peppol Access Point. However, we are cognizant that the regulations do not represent Belgium’s final technical specifications. A Royal Decree will confirm the technical aspects concerning Belgium’s e-invoicing solution. We await these with a view to definitively committing to support for the mandate. We continue to monitor further updates provided by the Belgian Federal Public Service Finance.