E-invoicing mandatory in belgium from 1 january 2026!

Did you know that “structured” electronic invoicing will become mandatory in Belgium from 1 January 2026 for just about all transactions between Belgian tax-liable companies (B2B) and permanent establishments of foreign entities/taxpayers carrying out activities in Belgium? We recommend that you also refer to our earlier article Keep yourself up to date with the latest developments on e-invoicing in Belgium. We would like to tell you more in this newsletter about the introduction of mandatory electronic invoicing in Belgium and offer some useful tips for when it is implemented.

 

 

 

What is “structured” e-invoicing?

E-invoicing is the process where an electronic invoice is created, sent and received in a structured electronic format that makes it possible to automatically and electronically process invoices. This offers various advantages over traditional paper invoices, including cost savings, efficiency and fewer errors.

Sending an invoice in PDF format via e-mail is not considered e-invoicing, even though it is a digital form of invoicing. This is because an unstructured PDF invoice cannot be drawn up, sent, received and processed automatically.

 

The PEPPOL network: the gateway for e-invoicing

But Europe has developed a framework for automating the processing of e-invoices, PEPPOL. PEPPOL (Pan-European Public Procurement On-Line) is a network and standard for electronic data exchange and was designed to enable companies – and public bodies – to exchange electronic documents (e.g., invoices) accurately and in accordance with common standards. Indeed, the goal of PEPPOL is to improve the efficiency and interoperability of e-invoicing, among other things.

PEPPOL features the following core components:

  1. PEPPOL eDelivery Network: A network of Access Points for the secure and reliable exchange of electronic documents.
  2. PEPPOL BIS (Business Interoperability Specifications): Standards for the structure and content of electronic documents (e.g., e-invoices).
  3. PEPPOL Access Points: Certified service providers that connect organisations to the PEPPOL network.
  4. PEPPOL SMP (Service Metadata Publisher): A directory that contains information on participants in the PEPPOL network, including what services and documents they can receive.

If, as a customer or supplier, you want to use the PEPPOL network, you first need to register your company with an authorised PEPPOL Access Point. Once the invoice is created, it is sent through the PEPPOL Network to the recipient. The PEPPOL Access Point will then convert the e-invoice into the correct format and ensure that it is delivered securely to the recipient. If you are the recipient, then the e-invoice will arrive through your PEPPOL Access Point and be automatically processed in your accounting system.

What can you do to prepare for the “structured” e-invoicing requirement?

Belgian legislation does not provide for a transition period to implement structured e-invoicing in your company. As a company, you should therefore take the following (preparatory) steps now so that your e-invoicing is ready by 1 January 2026 and you avoid VAT fines:

  1. Analyse and evaluate your current invoicing process: What is your current invoicing process, and what parts of it need to be digitised? What adaptations are needed so that you comply with the e-invoicing requirements?
  2. Choose the right software and invoicing process: Choose an invoicing system that supports e-invoicing and is compatible with the required standards. Join a PEPPOL Access Point to send and receive electronic documents (e.g., invoices) securely and in a standardised manner.

For small SMEs and the self-employed who use a subscription formula, there is also an additional financial incentive in the taxable periods 2024 until 2027, in the form of a higher cost deduction of 120% on the invoicing packages. The extra cost that small SMEs and the self-employed pay for their existing software subscription due to e-invoicing is therefore eligible for the higher cost deduction of 120%, provided that the extra cost (for e-invoicing) is shown separately on the invoice for the package.

  1. Awareness of e-invoicing within your company: Make sure your employees are aware of what e-invoicing entails. Organise technical training for employees who are directly involved in drawing up and processing your company’s invoices.
  2. Adaptations to your IT infrastructure: Make sure your new e-invoicing system is well integrated with your existing accounting system, and implement security measures to ensure the integrity and confidentiality of e-invoices.
  3. Test the new e-invoicing system: Conduct in-depth tests and gather feedback from your employees to make sure your e-invoicing is tip top.
  4. Implementation and monitoring: Roll out the new system in phases so you can rapidly identify and resolve problems. It is best to track the performance of the new e-invoicing system and envisage regular updates and improvements.
  5. Communicate with your suppliers and B2B customers: Inform suppliers and B2B customers that you are switching to e-invoicing and what that entails (e.g., via email).
  6. Retention requirements and compliance: Make sure you comply with the legal retention requirements for e-invoices. Conduct regular checks to make sure you are still in compliance with all the requirements.

 

Useful resources

 

– E-invoicing in Belgium: https://einvoice.belgium.be/en

– FAQ e-invoicing: https://finance.belgium.be/en/enterprises/vat/e-invoicing

– PEPPOL: https://peppol.org/

 

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If you have any questions, please do not hesitate to contact Amber Rogiers, Eline De Schepper, Damian Brodzinski or your usual contact within Monard Law.

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