E-invoicing mandates · Belgium
Belgium's B2B e-invoicing mandate, and why it is a Peppol mandate
Since 1 January 2026 every Belgian VAT-registered business must issue and receive structured electronic invoices to and from other Belgian businesses. No phase-in by size, and the rule names Peppol BIS over the Peppol network as the default. Below: what the law says, who is out of scope, and what the network actually looks like today.
In force since 1 January 2026
Live Peppol adoption · Belgium
Live Peppol adoption · Belgium
- Belgian Peppol IDs indexed
- 2,193,839
- Share of the whole network
- 22.9%
- Rank of 122 countries
- #2
- Change in 30 days
- +77,589
These are participant identifiers our index resolves, not companies: one organisation can hold several Peppol IDs, typically an enterprise number and a VAT number. The change figure moves for two reasons — companies being published to the network, and our own discovery passes resolving identifiers that were already registered — so read it as index coverage rather than as a pure joiner count.
Index updated 20 September 2026 · GET /v1/stats/participants
The calendar
What is required, and when
- 1 Mar 2024 B2G first. Electronic invoicing to Belgian public buyers became mandatory for contracts published after this date, generally from €3,000 excluding VAT — and below that threshold too for federal authorities.
- 1 Jan 2026 B2B, everyone at once. Structured electronic invoicing between Belgian VAT-registered businesses, per the Law of 6 February 2024. No size-based phase-in. Two measures applied from the same day: non-established taxable persons are excluded, and the FPS Finance fall-back guidance described below started to apply.
- 31 Mar 2026 Tolerance window closed. A three-month tolerance ran to the end of March for businesses that could show timely effort. It was never a postponement, and the FPS Finance notice of 7 April 2026 confirmed the general tolerance is over.
- 30 Jun 2026 Self-billing tolerance ended. The one remaining targeted tolerance, for self-billing arrangements, expired. Beyond that, the administration analyses individual situations on request.
- 1 Jan 2028 Two things pencilled in. The article 56 flat-rate scheme, one of the current send exemptions, ends by this date. E-reporting — sending transaction data to the administration, replacing the annual customer listing — sits in the federal coalition agreement with 2028 timing but has not yet been transposed into Belgian law. Today, nothing from your invoice is sent to the tax authority.
Scope
Who it applies to, and who is out
The obligation bites between a Belgian VAT-taxable supplier and a Belgian VAT-taxable customer. Sending and receiving are treated separately, and several groups are excused from one but not the other.
- No duty to send. Bankrupt taxable persons; businesses performing only article 44 exempt supplies; taxable persons not established in Belgium with no fixed establishment here, even when Belgian VAT-identified; and businesses under the article 56 flat-rate scheme. Article 44 also bites per transaction: an exempt supply that carries no invoicing duty carries no e-invoicing duty either, whatever the rest of the supplier's activity looks like.
- No duty to receive. Article 44-only businesses, and the non-established without a fixed establishment.
- In scope, despite common belief. The small-business exemption scheme up to €25,000 is covered, and so is the special agricultural scheme, at least for receiving. Being too small to charge VAT does not put you outside the mandate.
- Selling only to consumers? You are not required to send structured invoices to them — but you must still be able to receive one from your own suppliers.
- Penalties. Royal Decree No. 44 sets €1,500 / €3,000 / €5,000 for a first, second and subsequent failure to hold the technical means to issue and receive, subject to a three-month gap between findings. The ordinary VAT invoicing fines continue to apply.
Peppol's role
Belgium wrote Peppol into the rule
Most national mandates specify a format and leave the transport to the market. Belgium did not. Article 13ter of Royal Decree No. 1, as introduced by the Royal Decree of 8 July 2025, requires invoices to be issued per the European standard as concretised in the Peppol BIS format in its UBL version, and transmitted via the Peppol transmission network. That is a default, not a closed door.
The derogation sits in article 13ter, §2 of the same Royal Decree, resting on article 53, §2bis of the VAT Code: by mutual agreement the parties may use another format and another transmission channel — the derogation is not limited to the format — as long as EN 16931-1 and CEN/TS 16931-2 are respected. But article 13quater closes the loop — a business using another format must still hold the technical means to issue and receive the article 13ter way. So the honest summary is that Peppol is the floor in Belgium, and any bilateral arrangement is something you build on top of it, not instead of it.
This is why Belgium is the most useful case study on this site. A mandate with a named default channel and no phase-in produces exactly the pattern we measure: identifiers published in bulk by providers rather than arriving one company at a time. Contrast France, where the law mandates an accredited platform and Peppol is optional.
Sources
Where these facts come from
Every date, threshold and amount above was read from an official Belgian source on 12 September 2026. They are the authority; we are not.
Official sources
- Law of 6 February 2024 amending the VAT Code (Belgian Official Gazette, 20 February 2024) — the obligation and its 1 January 2026 entry into force.
- Royal Decree of 8 July 2025 — articles 13ter and 13quater of RD No. 1 (Peppol BIS UBL over the Peppol network) and the RD No. 44 penalties.
- FPS Finance — the official Belgian e-invoicing portal: guidance, FAQ and the e-reporting position.
- FPS Finance — who the obligation applies to (Dutch; a French version exists, there is no English one).
- FPS Finance — end of the general tolerance period, notice of 7 April 2026.
PeppolStatus measures the Peppol network. This page summarises published law to explain what we measure; it is monitoring and market data, not legal or compliance advice. Check your own position against the official sources above or with your accountant.
Next steps
What to do with this
- Find a providerEvery access point and SMP operator on the network, ranked by the participants they really serve, with measured uptime.
- Check a companyEnter a KBO/BCE or VAT number as a Peppol ID and see whether it is reachable, through whom, and since when.
- Check your softwareWhich access point Billit, Odoo, CodaBox and the rest actually run on, measured from the network.
FAQ
Belgian e-invoicing: common questions
Is e-invoicing mandatory in Belgium?
Yes. Since 1 January 2026, Belgian VAT-registered businesses must issue and receive structured electronic invoices for their transactions with each other. The obligation comes from the Law of 6 February 2024 amending the VAT Code, and it arrived for everyone at once — unlike France or Germany, Belgium set no phase-in by company size. A PDF attached to an email is not a structured electronic invoice and does not satisfy it.
Does the Belgian mandate require Peppol?
Peppol is the default, and this is what makes Belgium unusual. The Royal Decree of 8 July 2025 writes the requirement as issuing per the European standard 'as concretised in the Peppol BIS format in its UBL version' and transmitting 'via the Peppol transmission network'. Parties may agree between themselves to use another format or channel, provided EN 16931-1 and CEN/TS 16931-2 are respected — but even then both sides must still hold the technical means to issue and receive the Peppol way. In practice: you need Peppol, and anything else is an addition on top of it.
Who is exempt from the Belgian e-invoicing obligation?
There is no duty to SEND for bankrupt taxable persons, businesses performing only supplies exempt under article 44, taxable persons not established in Belgium and with no fixed establishment here (even if Belgian VAT-identified), and those under the article 56 flat-rate scheme, which itself ends by 1 January 2028. The article 44 exclusion also works transaction by transaction: a supply exempt under article 44 that carries no invoicing duty in the first place carries no e-invoicing duty either, even when the supplier is otherwise fully in scope. There is no duty to RECEIVE for article 44-only businesses and for the non-established. The small-business exemption scheme up to €25,000 is NOT exempt: it is in scope. Firms that invoice only consumers are not obliged to send structured invoices, but must still be able to receive them.
What happens if a Belgian customer cannot receive a Peppol invoice?
FPS Finance accepts a fall-back — administrative guidance, not a rule written into the Law or the Royal Decree. Where the recipient is technically unable to receive a structured invoice, the supplier may still invoice on paper, or in another electronic form such as a PDF provided the customer agrees to that form. That does not excuse the recipient — the duty to become able to receive stays with them. The general three-month tolerance on penalties covering January to March 2026 has ended; the FPS Finance notice of 7 April 2026 confirmed that, leaving only a targeted tolerance for self-billing that ran to 30 June 2026, plus case-by-case analysis on request.
What are the penalties in Belgium?
Royal Decree No. 44 sets a specific fine for not holding the technical means to issue and receive structured electronic invoices: €1,500 for a first breach, €3,000 for a second and €5,000 thereafter, with a three-month gap rule between findings. The existing VAT fine regimes for invoicing failures continue to apply alongside it.
How many Belgian companies are actually on Peppol?
We index 2,193,839 Belgian Peppol participant identifiers, which is rank #2 of 122 countries on the network. Belgium is the clearest example anywhere of what a same-day mandate does to a network: the identifiers were published in bulk by providers rather than trickling in. The count on this page is refreshed daily from GET /v1/stats/participants, and you can check any single company with our directory lookup.