B2B Electronic Invoicing Belgium 2026: The Complete Guide
As of January 1, 2026, all Belgian companies subject to VAT must issue and receive their B2B invoices via the PEPPOL network. A PDF sent by email is no longer compliant. Here is everything you need to know about this obligation. Structured electronic invoicing has been mandatory in Belgium since January 1, 2026. The three-month grace period announced by the Federal Public Service (FPS) Finance expired on March 31, 2026. Fines are now in effect. This guide provides a complete overview of the obligation, penalties, and steps to achieve compliance.
Grace period expired.The FPS Finance announced on December 2, 2025, a grace period for the first quarter of 2026. It ended on March 31, 2026. Since April 1, 2026, fines apply without mandatory prior warning.
What the law says exactly
The obligation for structured electronic invoicing for B2B transactions in Belgium is based on two legal texts:
- The law of February 6, 2024: approved by the Belgian Parliament on February 1, 2024, and published in the Belgian Official Gazette on February 20, 2024. It establishes in the VAT Code the obligation to issue and receive structured invoices for B2B transactions between VAT-subject companies.
- The Royal Decree of July 8, 2025: specifies the application procedures, compliant formats, the penalty regime, and the rounding rules for VAT. This text establishes the financial sanctions.
The effective date is January 1, 2026. There are no exemptions based on the size of the business: the obligation applies to all businesses subject to VAT in Belgium, from freelancers to large companies.
Activating PEPPOL in Odoo Enterprise is done in a few steps in the Accounting module. It is one of the first configurations we carry out on every Odoo project in Belgium since 2026.
What an electronic invoice really is
There is frequent confusion on this subject, and it costs those who make it dearly. A legal electronic invoice is not a PDF sent by email. A PDF is a dematerialized invoice, but not a structured electronic invoice.
A compliant electronic invoice is a file in a structured format that can be automatically read by accounting software, without human intervention. In Belgium, the chosen format is Peppol BIS Billing 3.0, based on the UBL 2.1 standard. This file contains the same information as a traditional invoice, but organized in a way that allows for automatic processing upon receipt.
Specifically, what this changes for your client: they no longer receive a document to read and re-enter into their software. They receive a file that their accounting software imports directly, without manual intervention. It is faster, less prone to errors, and traceable.
Sending a PDF by email after January 1, 2026, to a Belgian client subject to VAT is sending an invoice that the VAT administration considers as not issued. Your client can legally refuse it. And you risk a fine on the invoice in question.
What the PEPPOL network is
PEPPOL stands for Pan-European Public Procurement OnLine. It is a decentralized international network that allows the secure exchange of electronic documents between businesses and administrations. Belgium uses it as a mandatory channel for B2B electronic invoicing.
The network operates like a "digital postal service." Each business registers with a PEPPOL access point. When you send an invoice via PEPPOL, your access point transmits it to your client's access point, which delivers it into their software. The transmission is secure, traceable, and confirmed.
An important point that many overlook:in Belgium, the government does not receive a copy of your PEPPOL invoices.The network is decentralized. Your invoices pass directly between private access points. This is very different from the Italian system (SDI), where all invoices go through a state platform. This situation will change around 2028 with the introduction of the e-Reporting system, sometimes called the "5th corner," which will automatically transmit VAT data to the SPF Finances.
To send and receive invoices via PEPPOL, your business must be registered on the network through a certified access point. Among the available access points in Belgium are: Odoo (natively integrated into the Enterprise license), Billit, Falco (Horus Software), and several other specialized providers.
Who is affected and who is not
The obligation applies to all Belgian companies subject to VAT for their domestic B2B transactions, regardless of size.
| SUBJECT TO THE OBLIGATION | EXEMPT FROM OBLIGATION |
|---|---|
| All VAT-registered businesses · self-employed individuals · SMEs and large companies · regulated professions · artisans, merchants · for their B2B invoices to Belgian clients also subject to VAT | B2C invoices (to individuals) · non-VAT registered under article 44 (general practitioners, dentists, psychologists...) · invoices to foreign clients · receipts · pro forma invoices · invoices for certain exempt operations |
Special case:if you invoice individuals (B2C), you are not required to send via PEPPOL. However, you must be able toreceivePEPPOL invoices from your suppliers, even if your main activity is B2C. The obligation to receive applies to all VAT-registered entities.
Fines provided for by the Royal Decree of July 8, 2025
The Royal Decree of July 8, 2025 introduces a system of progressive fines. Sanctions apply per detected violation, with a grace period of three months between two violations.
- First violation: €1,500per detected non-compliant invoice
- Second violation: €3,000(if detected more than three months after the first)
- Third violation and subsequent: €5,000per violation
The three-month grace period means that a new offense is counted as a "recidivism" only if it is detected at least three months after the previous one. On the other hand,the administration is not required to issue a warning before imposing a fine.In theory, a penalty can be applied as soon as the first detection of an offense occurs.
The consequences go beyond administrative fines. If an invoice was supposed to be transmitted via PEPPOL and it was not, the VAT administration may consider that it was not issued. This can challenge the deductibility of VAT on the corresponding purchases on the client side, creating a cascade of accounting complications.
Concrete example:you are a freelance graphic designer and you send a PDF invoice of €2,000 to a Belgian communication agency in April 2026. The agency is subject to VAT. You risk a fine of €1,500, which is 75% of the amount of your invoice. And the agency can legally refuse to pay as long as it does not receive a compliant invoice.
The tolerance period: what you need to know
The Federal Public Service Finance announced on December 2, 2025, a tolerance period for the first quarter of 2026. During this period, no fines were applied to businesses that could demonstrate that they had made reasonable efforts to comply, and that the delay was beyond their control.
This tolerance ended on March 31, 2026. It did not constitute a general exemption: businesses that had not made any arrangements did not benefit from it. Since April 1, 2026, penalties apply without any additional grace period.
If your client is not yet registered on PEPPOL and you cannot send them a compliant invoice, it is they who are in violation, not you. In this case, you can temporarily send them a PDF invoice, provided you include an explicit request for them to activate their PEPPOL inbox for future exchanges.
At Wappli, we activate and configure PEPPOL in Odoo for each Belgian client from the start of the project. Compliance has been part of the standard scope since 2026.
A new VAT rounding rule
The AR of July 8, 2025, also introduces an important technical change in the calculation of VAT. Until now, some software rounded VAT line by line on an invoice. From now on, rounding must be done at the total amount of the invoice, not on each line individually.
This change may seem minor, but it has practical consequences: invoices generated by software that has not been updated may produce VAT amounts slightly different from those expected. If your invoicing software has not integrated this rule, your invoices may be technically non-compliant even if you are registered on PEPPOL. Check that your solution has properly applied this update.
How to achieve compliance: the steps
If you are not yet compliant, here is the procedure to follow.
Step 1: choose a PEPPOL software or access point
You need software or a service that generates invoices in the Peppol BIS Billing 3.0 format and allows you to send and receive them via the network. The options available in Belgium include specialized invoicing software (Billit, Falco, Peppol Box), ERPs that natively integrate PEPPOL (Odoo Enterprise), and dematerialization solutions that connect to your existing system via an API.
Step 2: Register on the PEPPOL network
To be reachable on PEPPOL, your company must be registered in the PEPPOL directory with your BCE business number (EAS identifier 0208). This registration is done through your access point. It is usually automatic when activating your account on a compatible platform.
Step 3: Update your customer records
To send invoices via PEPPOL, you need to know the PEPPOL identifier of each of your VAT-registered customers. In Odoo, this setting is done on each customer's record. For a large number of customers, bulk import via Excel file is possible. For customers who are not yet registered on PEPPOL, you need to contact them to ask them to do so.
Step 4: Inform your suppliers
To receive compliant invoices from your suppliers, they must know your PEPPOL identifier. Communicate it to your main suppliers and ask them to use this channel for all your future invoices.
Step 5: Test before fully switching over
Most solutions allow you to send test invoices before the actual production goes live. Take this opportunity to check that the formats are correct, that your clients receive them properly in their software, and that the VAT amounts are displayed according to the new rounding rules.
The tax advantage of the transition
To facilitate the adoption of electronic invoicing, the Belgian government has provided a tax incentive. For the taxable periods from 2024 to 2027, SMEs and self-employed individuals can benefit from atax deduction increased by 120%on subscription fees for electronic invoicing software and consulting services for their implementation.
How to benefit from it:this deduction applies to software subscriptions (not to one-time purchase licenses), only on the additional cost related to electronic invoicing. It falls under de minimis aid. Check the exact conditions with your accountant before applying it, as the specific criteria may vary depending on your status.
If you are a Walloon SME, business vouchers can also finance part of the support related to your compliance. Wappli is an approved provider of business vouchers in Wallonia for digital maturity projects, which includes support for the implementation of electronic invoicing.
What PEPPOL changes in the long term
PEPPOL is the first step in a deeper transformation of B2B exchanges in Europe. The European ViDA directive (VAT in the Digital Age) aims to generalize electronic invoicing for all cross-border B2B transactions in the EU by 2030.
In Belgium, the next step is e-Reporting, scheduled for 2028. It will involve automatically transmitting VAT data from all invoices (amounts, rates, VAT numbers of the parties) to the Federal Public Service Finance in almost real-time. Unlike the current PEPPOL, the government will this time have access to the data of each transaction. For companies already set up on PEPPOL, this evolution will be a natural extension of the existing system.
Becoming compliant now also prepares the ground for upcoming obligations rather than chasing after each regulatory deadline.
Key takeaways
Structured electronic invoicing via PEPPOL has been mandatory in Belgium since January 1, 2026, for all B2B transactions between VAT-registered businesses. The grace period for the first quarter of 2026 has ended. The fines stipulated by the Royal Decree of July 8, 2025, amount to €1,500, €3,000, and then €5,000 depending on the number of violations observed.
A PDF sent by email is not compliant. Compliance requires software or a service connected to the PEPPOL network, registration in the PEPPOL directory, and the configuration of your clients' PEPPOL identifiers.
If you are using Odoo Enterprise, PEPPOL compliance is included in your license at no additional cost per document. If you are using other software, ensure that it has integrated the VAT rounding update required by the Royal Decree of July 8, 2025, in addition to PEPPOL connectivity.
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