An e-invoice is not merely the sending or receiving of an invoice in PDF format. An e-invoice is an invoice that is presented in a structured xml file extension format using the UBL (Universal Business Language) standard. This type of file is recognized and used by most accounting software. E-invoicing is the automatization of the complete process from a supplier’s issuance of its invoice to the client’s receiving and processing of this invoice. In other words, it is an automatic exchange of data between the financial systems used by the sender and the receiver without the need for any human involvement in the process (“machine to machine”).
Legislative update
- The law mandating the use of e-invoicing in B2B transactions (i.e., transactions carried out by taxable legal entities in Belgium or foreign companies that have a Belgian VAT number) has been approved and enters into force on 1 January 2026.
- This means that all companies that have been incorporated (and are taxable) in Belgium MUST issue and receive electronically structured invoices for all their B2B transactions. This applies also to taxable entities that are incorporated outside of Belgium but have permanent establishments here.
- Mandatory e-invoicing will apply to only transactions that (i) are not exempt under Article 44 of the VAT Code and (ii) must be considered to have taken place in Belgium (i.e., a transaction that has been carried out for a taxable buyer who must disclose its Belgian VAT number for the transaction).
- There are several exceptions to this obligation, such as invoicing to consumers (B2C transactions with non-taxable buyers).
What must you do?
- Become familiar with the legislation: Contact us if you have any questions or if you need more information. That way, you can align your business timely with mandatory e-invoicing rules.
- Evaluate your invoicing process: See if the invoicing system you’re using now is compatible with e-invoicing.
- Choose an e-invoicing solution: There are different e-invoicing solutions available. They range from simple software to extensive platforms. Choose a solution that caters to your needs and budget.
- Use a third party to fulfil the obligation to receive e-invoice: If you or your invoice recipient does not have the necessary computerized means for e-invoicing, you can (temporarily) call on third-party services that provide technical solutions. One example is the HERMES web application platform. This is a temporary solution that one can use (during the transition period up to 1 January 2026) if the you or the invoice recipient is not yet recognized in the Peppol network.
- PEPPOL BIS (Pan-European Public Procurement Online): In response to other Member States’ systems, Belgium uses the Peppol network for the exchange of standardized electronic invoices. For this, you must identify yourself by using a PEPPOL ID.
- Test your e-invoicing software: Make sure that your e-invoicing software runs properly.
- Inform your business partners: Let your business partners know that you will (have to) use e-invoicing as from 1 January 2026 (at the latest).
Stay informed
More details about how Belgium will implement e-invoicing will become available in the coming months. We’ll surely keep you posted on this.
