Regulatory updates - Belgium

The royal decree published on July 8 provides taxpayers clarification on e-invoicing obligations that commence on January 1, 2026, and continues to promote alignment with the ViDA directive. The legislation acknowledges that electronic invoices serve as the basis for electronic reporting systems, and the automation aspect provides efficient compliance and control initiatives.

The following aspects are more specifically clarified within the decree:

Technical Standards and Interoperability — Peppol will be the default transmission method for invoices; however, upon mutual agreement, trading parties may opt for other methods compliant with EN-16931 or CEN/TS 16931 standards.

Mandatory Peppol Capabilities — Trading parties may agree on other standards, but taxpayers must still have the technical capabilities for issuing and receiving invoices via Peppol.

Rounding Rules for VAT invoices — Structured invoices may only be rounded at the VAT total amount. This is no longer permissible per line item.

Penalties for non-compliance — Failure to comply with technical capability requirements for issuing and receiving electronic invoices will incur fines of:

• 1500 EUR — first offense
• 3000 EUR — second offense
• 5000 EUR — third offense

Penalties can only be applied 3 months apart from the previous infraction.

The decree also makes strong mention of Peppol acting as a solution for the anticipated near real-time reporting obligations expected to commence in Belgium to further align with ViDA.

According to the Belgian FPS’s (Federal Public Service Finance) e-invoicing website, the mandate will now exempt Belgian VAT payers not established in Belgium and without a permanent establishment.

This clarification emphasizes that the upcoming obligations for e-invoicing in Belgium will primarily apply to Belgian taxpayers registered for VAT with fixed establishments on Belgian soil.

The above exemptions are focused on e-invoicing obligations upcoming in 2026 but are subject to change in the context of the future near real-time reporting requirements set to commence in 2028.

This marks yet another stride made by Belgium in its attempts to combat tax evasion. The new obligations are expected to complement the fast-approaching e-invoicing obligations set to begin in January 2026.

The near real-time reporting requirements include automatic data transmission to Belgium's tax authority. Furthermore, the transmission system is expected to integrate cash registers and payment and invoicing systems.

The Belgian government has yet to clarify the outline of the obligations and exact timelines; however, it is likely that Belgium is clarifying its commitment to evolving the expected B2B e-invoicing requirements into a 5-corner model, firmly aligning with the ViDA proposal.