E-invoicing in Belgium from 2026: what every business needs to know
Belgium became one of the first EU member states to make structured B2B e-invoicing mandatory for all VAT-registered businesses established there. The obligation took effect on 1 January 2026, and it applies regardless of company size or sector. Belgium’s B2B e-invoicing obligation applies to suppliers established in Belgium; a foreign supplier without a Belgian establishment is outside it, even with a Belgian VAT number.
This post walks through what the mandate requires, who it covers, what Peppol and Factur-X are, what happens if you do not comply, and what the evidence layer looks like once you have the format right.
What the mandate requires
Belgian law now requires every B2B invoice to be:
- Structured. The invoice must be machine-readable, meaning the data fields (VAT number, line items, totals, payment terms) are in a defined XML schema, not just rendered as visual text inside a PDF.
- Sent over Peppol, unless agreed otherwise. Peppol BIS over the Peppol network is the default, but supplier and customer may agree on another EN 16931-compliant format and another digital channel. On the Peppol route, both parties need an Access Point.
- Compliant with Peppol BIS Billing 3.0, by default. This is the document specification used across most of Europe: UBL XML with specific mandatory elements.
A plain PDF invoice, even one with a pretty layout and all the right figures, is no longer compliant for Belgian B2B transactions. Neither is a CSV export or an EDI message in a legacy format.
Who it applies to
The mandate covers every VAT-registered business established in Belgium issuing invoices to other Belgian VAT-registered businesses. That includes:
- Self-employed individuals registered for VAT
- SMEs
- Large enterprises
- Foreign companies with an establishment in Belgium
It does not currently cover B2C transactions (invoices to private individuals) or transactions where the customer is not registered for VAT in Belgium.
If you are a non-Belgian business without a Belgian establishment invoicing a Belgian B2B customer, you are outside the obligation, even with a Belgian VAT number. Your customer may still prefer to receive your invoices over Peppol.
The Peppol network: a brief explanation
Peppol stands for Pan-European Public Procurement On-Line. It started as a procurement network for government contracts and has become the de facto B2B invoicing backbone across Europe.
Peppol uses a four-corner model:
- Corner 1: you (the sender), connected to your Access Point
- Corner 2: your Access Point, which routes the document
- Corner 3: your trading partner’s Access Point, which receives it
- Corner 4: your trading partner (the receiver)
You do not connect directly to the Peppol network. You connect via a certified Access Point provider, which handles the routing. Most cloud accounting platforms (Exact, Twinfield, Billit, Yuki, and others) now offer Peppol connectivity built in or as an add-on.
To receive invoices, your VAT number must appear in the Peppol Directory, the public registry of all reachable parties. If a business looks you up and you are not listed, they cannot send you a compliant invoice.
Factur-X and ZUGFeRD: the hybrid format
Peppol transmits UBL XML. That works well for machine-to-machine processing, but UBL XML on its own is not human-readable in any practical sense. This is where Factur-X (and its German counterpart ZUGFeRD) comes in.
Factur-X is a hybrid format: a PDF/A-3 file that embeds the CII XML invoice data as a structured attachment. Open it in any PDF viewer and you see a normal-looking invoice. Open it in an accounting system and you can extract the machine data directly. Both representations are bit-identical to what was transmitted, both are inside a single container.
Belgian law does not prescribe an archive format: what it requires is that the authenticity and integrity of the invoice stay guaranteed throughout the retention period. A Factur-X copy next to the Peppol invoice is one way to keep a human-readable version alongside the structured data.
Timeline
| Date | Obligation |
|---|---|
| 6 February 2024 | Law introducing mandatory B2B e-invoicing |
| 8 July 2025 | Royal Decree with the implementing rules |
| 1 January 2026 | Mandatory B2B e-invoicing for all VAT-registered businesses established in Belgium, Peppol by default |
| Ongoing | Tax authority audits and enforcement |
There is no revenue-based phase-in. The obligation applied to all sizes from day one.
What you need to do
If you have not already acted:
- Register with a Peppol Access Point. Your accounting software may already offer one. If not, standalone Access Point providers operate across Belgium.
- Check that your VAT number appears in the Peppol Directory. You can verify this at our Peppol Check tool: paste in your VAT number and we tell you within two seconds whether you are reachable.
- Run your key trading partners through the same check. Anyone showing as not reachable needs to register before you can send them a compliant invoice.
- Confirm that your software can generate Peppol BIS Billing 3.0 UBL XML, not just a PDF or a legacy EDI format.
- Set up compliant archival. Belgian tax law requires invoice retention for seven years. The law prescribes no archive format; a PDF/A-3 copy with the XML embedded keeps the structured data and a human-readable version together.
Penalties for non-compliance
The Belgian tax authority (FPS Finance) can apply penalties for non-compliant invoicing. Under Belgian VAT law, an invoice that does not meet the legal form requirements can be treated as if no invoice was issued, which means the associated VAT deduction is at risk for the buyer.
Practically, this means:
- Buyers can refuse non-compliant invoices
- VAT deductions based on non-compliant invoices may be disallowed during an audit
- Repeated non-compliance can trigger administrative fines
The focus in the first months of 2026 has been on facilitating transition rather than immediate enforcement, but that window closes as the year progresses.
The evidence gap
Getting the format right is necessary but not sufficient. The deeper question is: can you prove, years from now, that the invoice you archived is identical to what was sent, and that it existed on the date you claim?
This is where the evidence layer matters. Two mechanisms close the gap:
RFC 3161 timestamps bind a cryptographic hash of your document to a signed timestamp from a trusted authority. If a tax inspector or court challenges whether an invoice was issued on a particular date, the timestamp is evidence they cannot easily dispute. Belgium’s archival requirements do not mandate RFC 3161. Under Article 41 of the eIDAS Regulation, an electronic timestamp cannot be refused as evidence just because it is electronic, and a qualified timestamp is presumed accurate.
Chain of custody means you can show an unbroken record from generation to archival: who created the document, when, which processing steps it passed through, and that none of those steps altered the content. SealDoc produces an evidence pack per invoice, on request. It always contains a compliance passport, the manifest and the manifest hash, plus, where they exist, the document, the chain of custody, the hash-chained ledger with its public keys, and the RFC 3161 token. Any of those elements can be verified offline.
Ready to check your Peppol status?
The fastest action you can take right now is to verify that you and your trading partners are reachable on Peppol. Our Peppol Check tool looks up any EU VAT number in the live Peppol Directory and tells you whether the party is registered, which document types they accept, and what they need to do to get compliant if they are not.
No account required. Paste the VAT number, get the answer.