e-Invoicing in Belgium: Applicability, Limit, Guidelines & Implementation Date

Across the European Union, e-invoicing has seen significant uptake, especially with the push for standardization to combat VAT fraud and improve fiscal efficiency. Belgium has been a proactive adopter of e-invoicing, and with new legislation set to mandate structured electronic invoicing (e-Invoicing) for most businesses by January 2026, 

it is crucial for Belgian enterprises to understand the implications, benefits, and requirements of this transition. This article provides a detailed overview of e-invoicing in Belgium, from its history and regulatory framework to implementation timelines, compliance requirements, and the benefits and challenges businesses may face.

What is e-Invoicing?

e-Invoicing, or electronic invoicing, is the process of issuing, sending, receiving, and processing invoices electronically in a structured digital format, usually through a standardized network like Peppol. 

Unlike traditional paper or unstructured PDF invoices, structured e-invoices are formatted in a way that allows for fully automated processing, reducing human intervention and error.

In Belgium, e-invoicing is aligned with the European standard EN16931, which defines the necessary elements and structure of an e-invoice, making it compatible with systems across the European Union. This standard is crucial for ensuring interoperability across borders and supports a seamless exchange of invoices between businesses and public authorities.

e-Invoicing Implementation Timeline in Belgium

Here's the e-Invoicing Implementation in Belgium outlining the key dates and mandates for B2B and B2G implementations:

The e-Invoicing Process in Belgium

Belgium’s e-invoicing process uses the Peppol network, which supports a structured and secure digital exchange of invoices. 

Businesses must use Peppol-compatible software to send and receive invoices, which are transmitted via the Mercurius platform (the official Belgian e-invoicing portal). 

For B2B transactions, e-invoicing is facilitated via the Peppol network and is straightforward:

1. Invoice Creation: Businesses generate a structured e-invoice following Peppol BIS 3.0 standards.
2. Submission via Peppol: The invoice is sent through Peppol’s secure network to the recipient’s system.
3. Automatic Processing: The receiver’s system processes the invoice automatically, facilitating approvals and payments.
4. Record-Keeping: Invoices are archived for compliance, with the Mercurius platform providing tracking and traceability.

Belgium's e-Invoicing Model

Belgium’s model for e-invoicing is platform-agnostic, meaning businesses can use any software that aligns with the Peppol framework. Peppol ensures interoperability, allowing suppliers and buyers to exchange invoices seamlessly. Belgium’s federal government supports this approach through Mercurius, which will serve as the central hub for e-invoices to public authorities.

Key Components

• Mercurius Platform: Belgium’s “mailroom” for public sector e-invoicing. Mercurius facilitates secure transmission and allows for both manual and automated invoicing.
• Peppol Network: A standardized network that ensures compatibility and structured data exchange.
• EN16931 Compliance: Belgium’s adherence to the European eInvoicing standard to promote interoperability within the EU.

Scope of e-Invoicing in Belgium

Belgium’s e-invoicing mandate affects different types of transactions:

• B2G (Business to Government): All public procurement contracts.
• B2B (Business to Business): Compulsory for Belgiun VAT-registered entities, excluding businesses conducting VAT-exempt operations such as non-aesthetic medical care, socio-cultural services, financial services, education, and specific transportation (e.g., for the sick or disabled) as per Article 44 of the VAT Code.
• International Invoicing: Allowed with the recipient’s consent, with Peppol often serving as the network of choice.

Who Needs to Comply with e-Invoicing in Belgium?

The mandate applies to:

• All VAT-Registered Businesses: Required to issue structured e-invoices by January 2026.
• Public Sector Suppliers: Obliged to use e-invoicing for B2G transactions for contracts above €3,000.

Exemptions from e-Invoicing in Belgium

From 1 January 2026, structured electronic invoicing is mandatory for most B2B transactions involving Belgian VAT-registered enterprises. Exemptions include:

B2C Transactions: Not required for private-use goods or services.

Low-Value Public Contracts: Mandatory for public contracts over €3,000

Specific B2B Exemptions:

• Bankrupted entities.
• VAT-exempt businesses under Article 44.
• Non-resident businesses without a permanent establishment.
• Entities under a flat-rate tax scheme (until 1 January 2028).

Benefits of e-Invoicing in Belgium

The shift to e-invoicing brings several advantages:

• Cost Reduction: e-Invoicing cuts costs by eliminating expenses for paper, printing, and postage. Automation reduces errors, lowers correction costs, and frees resources.
• Process Automation and Efficiency: Automation minimizes manual tasks, speeding up workflows and reducing processing time. Faster invoice approvals improve productivity and save valuable resources.
• Enhanced Cash Flow: Shortened payment cycles improve cash flow for suppliers and allow buyers to benefit from early payment discounts. Reliable cash flow improves financial stability for both parties.
• Improved Compliance, Security, and Transparency: e-Invoicing creates secure, traceable transactions with clear audit trails, ensuring compliance with regulatory standards and reducing fraud. This transparency fosters trust among business partners.
• Environmental Benefits: e-Invoicing conserves resources by reducing paper use, lowering the carbon footprint associated with production and transport. 

Technical Rules for Electronic Invoicing

To ensure the accuracy and reliability of e- invoices, specific technical rules must be followed from the point of issuance through the retention period. 

• Invoice Modifications: Any changes to an invoice must directly reference the original and follow the same electronic format as the initial invoice.
• Ensuring Authenticity of Origin: This confirms the identity of the supplier or issuer, with both parties (sender and receiver) guaranteeing the invoice’s authenticity.
• Maintaining Content Integrity: Invoice details must remain unchanged, complying with VAT Directive standards.
• Ensuring Legibility: Invoices must be legible throughout the retention period, with clear and accessible VAT data for accurate reference..
• Audit Trail Verification: An audit trail should directly connect an invoice to the actual transaction, using third-party documents, supplier records, or internal controls to confirm accuracy.

How to Prepare for e-Invoice Implementation as a Business

Businesses must take specific actions to comply with Belgium’s mandatory e-invoicing requirements:

• Assess Current Systems: Determine if your accounting or ERP software supports the Peppol network and Belgium’s structured e-invoicing standards (EN16931). Verify compatibility with the Mercurius platform for public sector transactions and identify if system upgrades are needed for automated invoice processing.
• Choose Compatible Software: Select e-invoicing software from the list of Peppol-compliant solutions provided by Belgian authorities. Confirm with software providers if they plan to support Peppol BIS 3.0 by January 2026.
• Integrate Business Systems (for Large Enterprises): Coordinate with IT and finance departments to connect internal systems with Peppol and Mercurius, ensuring smooth data flow. For complex setups, consider consulting with certified e-invoicing solution providers to meet Belgium’s e-invoicing requirements.
• Establish Internal Controls: Set up verification and validation controls to ensure compliance with standards for authenticity, integrity, and readability. Implement approval workflows to streamline reviews and create a reliable audit trail for VAT reporting.
• Train Staff: Provide training on using the Peppol network and Mercurius platform if engaging in B2G transactions.
• Engage with Vendors and Clients: Coordinate with suppliers and customers to confirm their readiness for structured e-invoices. Establish self-billing agreements where relevant, ensuring invoices meet the structured format requirements.

Challenges of e-Invoicing for Businesses in Belgium

Despite its benefits, e-invoicing poses some challenges:

• Technical Upgrades: Businesses may face upfront costs for upgrading systems.
• Adaptation Period: Smaller businesses may need time to adjust to new invoicing formats.
• Compliance Complexity: Understanding and following structured data requirements might require training and adaptation.

How ClearTax Can Help Your Business with e-Invoicing in Belgium

ClearTax offers a comprehensive e-invoicing solution that simplifies compliance and streamlines the e-invoicing process for businesses in Belgium. 

• End-to-End e-Invoicing Solution Provider: ClearTax provides a complete e-invoicing solution, from invoice generation to submission, ensuring businesses meet Belgium’s structured e-invoicing requirements.
• Integration with Government e-Invoicing Systems: ClearTax seamlessly connects your business systems to Belgium’s government e-invoicing infrastructure, including the Peppol network and Mercurius platform, for efficient B2G transactions.
• Peppol-Compliant Service Provider: As a Peppol-certified provider, ClearTax ensures your invoices comply with EN16931 standards, facilitating smooth and secure exchanges with both local and cross-border clients.
• Web Portal for Bulk e-Invoice Generation and Tracking: our user-friendly portal allows businesses to generate e-invoices in bulk, track invoice status, and manage invoices at scale, with advanced reporting and analytics features.
• 100% Compliance with Belgian e-Invoicing Regulations: ClearTax guarantees compliance with Belgium’s evolving e-invoicing mandates, including VAT, syntax standards, and regulatory timelines, keeping your business aligned with the latest legal requirements.
• Automated Status Tracking and Archiving: With ClearTax, businesses can easily monitor the status of submitted invoices, receive notifications, and archive invoices securely to meet VAT audit and retention requirements.
• Detailed Reporting and Audit Support: ClearTax’s reporting tools provide visibility into invoice processing, making it easy for businesses to manage VAT reporting, maintain a reliable audit trail, and generate detailed reports for tax filings.
• Enhanced Security and Data Privacy: ClearTax prioritizes data security and ensures compliance with EU data protection regulations, offering secure encryption and access controls for sensitive financial data.

Conclusion

Belgium's shift to mandatory e-invoicing is a significant step towards digitizing financial transactions, enhancing compliance, and promoting efficiency across both public and private sectors. With structured electronic invoicing (e-invoicing) becoming compulsory for B2G transactions in March 2024 and for nearly all B2B transactions by January 2026, Belgian enterprises need to prepare by adopting compatible systems and processes that meet the Peppol standards.

This transition, while offering substantial benefits in cost reduction, process automation, and compliance, requires businesses to adapt their internal systems, train staff, and establish robust controls. 

ClearTax offers a solution that enables businesses to comply with these regulatory requirements smoothly, providing end-to-end compliance with Belgian e-invoicing rules.