Technical Rules for e-Invoicing in Belgium: A Detailed Guide

Updated on: Dec 16th, 2024

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9 min read

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Belgium, as part of its ongoing digital transformation and in line with European Union directives, is implementing e-invoicing for VAT registered businesses. This transformation, particularly for B2B (business-to-business) transactions, is designed to streamline administrative processes, reduce fraud, and improve efficiency in financial reporting. 

This article provides a comprehensive overview of the technical rules governing e-invoicing in Belgium, the framework and formats involved, and the role of the Peppol network.

Mandatory Use of Structured Electronic Invoices from 2026

From January 1, 2026, structured electronic invoicing will be compulsory for all B2B transactions between Belgian businesses subject to VAT. This means that businesses will need to issue invoices in a format that can be automatically processed, making it easier for both tax authorities and businesses to handle and track transactions.

Key Points:

  • B2B transactions: Structured electronic invoices will be mandatory for nearly all transactions between Belgian enterprises subject to VAT.
  • B2C transactions: The mandate does not apply to invoices for goods or services provided to individual consumers.
  • B2G transactions: Starting March 1, 2024, electronic invoicing has been compulsory for contracts with public authorities valued at €3,000 or more.

Exceptions: Some limited exemptions apply, such as businesses that are bankrupt or carry out exempt transactions under the VAT code.

Key Characteristics of Structured Electronic Invoices

A structured electronic invoice is one that is created, sent, and received in a format that allows automatic processing by computers. Unlike a traditional PDF or paper invoice, a structured e-invoice contains data that is machine-readable, meaning it can be automatically parsed and processed by accounting and tax systems.

To comply with the e-invoicing regulations, invoices must meet the following technical requirements:

  • European Standards: Invoices must adhere to the EN 16931-1 and CEN/TS 16931-2 standards, which define the rules for invoice data, format, and structure. 
  • Mandatory Elements: The invoice must contain all mandatory data elements such as the supplier’s and buyer’s VAT numbers, invoice number, date, payment terms, and the value of goods or services sold.
  1. Peppol-BIS Format: The invoice must be formatted using the Peppol-BIS document type, which follows the EN 16931 European standard. This ensures the invoice can be processed and exchanged automatically via the Peppol network.

Technical Rules for e-Invoicing in Belgium

When it comes to electronic invoicing, ensuring the authenticity of the origin, the integrity of the content and the legibility of the invoice are fundamental requirements. As stipulated in VAT regulations, these conditions must be maintained from the moment the invoice is issued until the end of its retention period.

Authenticity of the Origin

The "authenticity of origin" refers to the assurance that the identity of the person who issued the invoice, either as the supplier of goods or provider of services, is properly verified. Both the sender (the supplier or service provider) and the recipient (the purchaser or service recipient) are responsible for guaranteeing the authenticity of the invoice's origin. This is crucial for ensuring that the transaction is legitimate and verifiable for VAT purposes.

Integrity of the Content

The integrity of the content ensures that the information on the invoice has not been altered after issuance. This includes maintaining all required details as per the VAT Directive. The integrity condition ensures that the invoice remains a true representation of the transaction and that any changes to the invoice are clearly referenced to the original document.

Legibility of the Invoice

The legibility condition mandates that the content of the invoice must remain clear and readable for the entire retention period, which typically spans several years. This means the VAT data should be easily readable without requiring excessive interpretation or effort.

For electronic invoices, this can be achieved if the document can be displayed on request, in a readable format, and within a reasonable time frame. The original electronic file and the readable version must match, ensuring there is no discrepancy in the data.

Electronic Invoices and Modifications

An electronic document that makes modifications to the original invoice—while clearly referencing the original—will also be treated as an electronic invoice, provided it follows the same format as the original document. This ensures that any updates or amendments to an invoice remain traceable and verifiable.

Retention of Invoices and VAT Compliance

The rules surrounding the authenticity, integrity, and legibility of invoices also apply to their retention and VAT compliance. From 1 January 2026, the conditions for structured electronic invoices will replace the previous reliance on paper-based invoices. The true nature of the invoice will be clearer, and audit trails will be more reliable for ensuring compliance with VAT reporting and deduction regulations.

Reliable Audit Trail

A reliable audit trail for VAT purposes is essential for verifying the connection between invoices and actual transactions. It must meet three key criteria:

  1. Traceability: The link between the supporting documents (such as invoices) and the transactions they relate to should be clear and easy to follow.
  2. Compliance: The audit trail must comply with applicable VAT procedures and regulations.
  3. Accuracy: The audit trail should reflect real processes that have actually occurred, such as the supply of goods or provision of services.

Sending and Receiving Invoices via Peppol

  • Sending Invoices: To send structured invoices, businesses must be connected to the Peppol network through a certified service provider. This involves using software that is Peppol-compatible, which could include ERP systems or invoicing software that supports the Peppol-BIS format.
  • Receiving Invoices: Similarly, businesses must ensure that they can receive invoices in the Peppol-BIS format. This might require updating accounting software or subscribing to a Peppol service provider.

The Peppol Network and Its Role

The Peppol (Pan-European Public Procurement Online) network is the backbone of Belgium's e-invoicing framework. It is an international, open network designed to facilitate the secure and standardized exchange of electronic documents, including invoices, between businesses and public authorities.

Peppol is designed to ensure that invoices can be exchanged in a way that guarantees they are secure, machine-readable, and compliant with European standards. The key benefits of Peppol include:

  • Interoperability: Peppol enables businesses to send invoices across borders to other businesses and public authorities in the same standardized format.
  • Security: The network ensures that data transmission is secure, reducing the risk of fraud and errors compared to email or paper-based invoicing.
  • Efficiency: Peppol supports the automated processing of invoices, making it easier for businesses to manage payments and reporting.

Peppol-BIS Format and EN 16931 

Issued invoices must comply with the Peppol-BIS (Business Interoperability Specifications) format, which is based on the EN 16931 European standard for electronic invoicing. This format allows invoices to be processed automatically and easily integrated into accounting systems. 

  • Peppol-BIS is a standardized set of rules that define the structure of invoices exchanged via the Peppol network.
  • The EN 16931 standard is the European framework that defines the technical and semantic requirements for electronic invoicing (e-invoicing) across the EU. It ensures that invoices exchanged between businesses and public entities meet strict compliance and interoperability standards. 

Invoice Formats: What Is Allowed and What Is Not?

Under the new rules:

  • PDF invoices: While PDF invoices are still legal until December 31, 2025, they will no longer be legally compliant for B2B transactions starting January 1, 2026. From that point onward, only structured electronic invoices in the Peppol-BIS format will be compliant.
  • Alternative Formats: While other formats, such as Excel or Word, are permissible before 2026 with the recipient’s consent, after the deadline, invoices must adhere to the EN 16931 standard in the Peppol-BIS format. Both parties must mutually agree upon any deviation from this.

Conclusion

Belgium is moving towards digital economy with mandatory structured e-invoicing by 2026 with the use of the Peppol network and compliance with European standards like EN 16931 and Peppol-BIS, Belgian businesses can automate their invoicing processes, reduce administrative burdens, and ensure VAT compliance. 

Businesses need to prepare for the full implementation by upgrading their systems and software to ensure they can send and receive structured e-invoices in the required formats. It 

The rules and guidelines provided above are part of a broader European initiative to standardize electronic invoicing and improve cross-border interoperability, helping businesses, tax authorities, and public authorities achieve greater efficiency and transparency in VAT reporting and invoicing practices.

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