Regulatory updates - Belgium

As part of a broader digitalization project that has been gradually rolled out by the Federal Public Service (FPS) Finance since January 1, 2025, the goal of the new VAT provisions is to offer greater flexibility and clarity to stakeholders, while encouraging compliance.  

Changes implemented from January 1, 2025, have included extended filing and payment deadlines for quarterly filers, the introduction of a formal response period for inquiries, and revised rules for VAT refunds. There has also been a removal of the possibility to file corrective periodic VAT returns after the legal deadline, adjusted penalties to reward compliant behavior, and more.  

The expected changes from May 1, 2026, center around the replacement of the VAT current account with the provisional VAT account. The following changes are to be implemented: 

• Centralized management via MyMinfin, where businesses can view and manage their financial position in one central portal. 

• The removal of the holiday system means that the summer filing extension is also discontinued. For this year only, no latefiling penalties apply if returns are filed within the former deadlines. 

• New bank account numbers for VAT payments will be introduced specifically for VAT payments. The new account number is BE41 6792 0036 4210. 

• Refund requests made via a VAT return are limited to the credit from that return, while remaining credits can be reclaimed through MyMinfin. 

Any VAT credit remaining as of April 30, 2026, will be automatically moved to the new VAT provision account, provided all VAT returns have been filed by that date. If any returns are still outstanding, the tax authorities will grant a short grace period to complete them. After this period, they will decide whether the credit can be refunded or used to settle outstanding amounts. 

Further information regarding the announcement made by FPS Finance can be found here. 

From January 1, 2026, Belgium will require all VAT-registered businesses established in Belgium to issue and receive structured electronic invoices (e-invoices) for domestic B2B transactions. This obligation is part of a broader VAT reform aimed at digitalization, fraud prevention, and alignment with the EU's "VAT in the Digital Age" (ViDA) directive.

Key features:

• E-invoices must comply with European standards (Peppol/EN 16931)
• The obligation applies to transactions where both supplier and customer are established in Belgium. The draft law reconfirms that non-established entities registered for Belgium VAT will be excluded from the scope.
• Fallback provision: If, for technical reasons, the recipient is not able to receive a structured e-invoice (e.g. lack of technical means), the issuer is temporarily not required to issue a structured e-invoice for that transaction. Instead, the issuer must still issue an invoice in another form (e.g., paper or PDF). However, this does not exempt the recipient from their obligation to become compliant.

More information can be found in the draft law about the various provisions on Value Added Tax (VAT) in the following link (Dutch and French).

FPS Finance has recently announced a three-month grace period, at the beginning of 2026, for Belgian taxpayers, acknowledging the significant operational challenges posed by the new e-invoicing requirements. During this transition period, companies that struggle to meet all obligations despite their best efforts will not face penalties. No sanctions will be imposed for non-compliance with the e-invoicing requirements throughout these three months.

The grace period, largely aimed at companies that have made sufficient implementation efforts but still face technical challenges, applies to the following infractions directly related to the new obligation:

• Companies that do not yet have the required technical capabilities to send and/or receive structured electronic invoices (either completely or for specific transactions, such as self-billing).
• Companies unable to issue structured electronic invoices despite being obligated to do so because their systems or third-party solutions do not yet support valid electronic invoice issuance.

Companies that have not made adequate preparations are urged to comply as soon as possible. The announcement explicitly states that, regardless of a grace period, the intention is not to grant a general extension of the mandate.

More information on the grace period announced by FPS Finance can be found here.