The short answer
Since 1 January 2026, almost every invoice between two VAT-registered businesses established in Belgium must be a structured electronic invoice in the Peppol BIS format, exchanged over the Peppol network through a certified service provider (an access point). A PDF sent by email no longer counts. Every VAT-registered company must also be able to receive these invoices, even under the small enterprise exemption scheme. The main exceptions are businesses doing only VAT-exempt activities under article 44 of the VAT Code and foreign businesses without a Belgian establishment. Lacking the technical means to send and receive costs 1,500 euros for a first offence, 3,000 for a second and 5,000 for each one after that; the tolerance period ended on 31 March 2026. E-reporting of invoice data to the tax authority is planned from 2028.
Everything below comes from FPS Finance's e-invoicing site (einvoice.belgium.be), its FAQ and the laws it links to, read on 1 October 2026. General information, not tax advice.
Who has to comply
If both the supplier and the customer are Belgian businesses subject to VAT, the invoice between them must be structured. In FPS Finance's words, if you have an active VAT number, the obligation applies to you. It rests on the law of 6 February 2024 and covers every invoice drawn up from 1 January 2026, even for work done in 2025. VAT status is public: the KBO shows "Subject to VAT since [date]" under a company's capacities. How the Belgian enterprise number works explains how it relates to the VAT number.
Situation | Must send structured invoices | Must be able to receive them |
|---|---|---|
VAT-registered company established in Belgium | Yes | Yes |
Small enterprise exemption scheme (turnover up to 25,000 euros a year) | Yes | Yes |
Flat-rate VAT scheme (article 56, ending by 1 January 2028 at the latest) | No | Yes |
Bankrupt VAT payer | No | Not exempted |
Only VAT-exempt activities under article 44 of the VAT Code | No | No |
Foreign business without a permanent establishment in Belgium, even with a Belgian VAT number | No | No |
Company selling only to private individuals | No, for those sales | Yes, from its suppliers |
Farmers under the special agricultural scheme are covered at least for receiving. Outside the obligation, a PDF stays valid: sales to consumers, international invoices, and any deal where one party is not subject to VAT. Invoicing public bodies has its own rules: electronic invoicing has been compulsory for contracts published after 1 March 2024, as a rule from 3,000 euros excl. VAT.
What counts as a structured e-invoice
VAT law knows two kinds of electronic invoice. An "ordinary" one, such as a PDF, has a free layout. A structured one is drawn up, sent and received in a form software can process without anyone retyping it. Only the second meets the obligation.
Format. It must follow the European standard EN 16931, which in practice means Peppol BIS. Another format needs both parties' agreement and must also meet EN 16931; FPS Finance recommends a written agreement.
Channel. Peppol, unless both parties agree otherwise. A customer cannot force you onto its own portal without your consent.
Credit notes. A credit note correcting a structured invoice is itself structured and goes through Peppol too.
Attachments and PDF copies. Attachments travel inside the same message, not by separate email. A PDF copy is optional, and the recipient cannot reject an invoice for lacking one.
How the access point model works
A company cannot register on Peppol by itself. It connects through a certified Peppol service provider, an access point, usually built into its invoicing, accounting or ERP software. FPS Finance compares it to a telephone network: once connected, you reach everyone else connected, whatever their provider. The FPS BOSA has been the Belgian Peppol Authority since 1 January 2016.
Your address on the network is your Peppol ID. Every Belgian company must be registered at least under its enterprise number (scheme 0208), and providers are contractually obliged to do this. To check a specific company, see how to check if a Belgian company is on Peppol.
Penalties and the tolerance period
The existing VAT fines for missing, late or incorrect invoices now also cover structured invoices. The Royal Decree of 8 July 2025 added a fine for not having the technical means to issue and receive them: 1,500 euros for a first offence, 3,000 euros for a second and 5,000 euros for each following one. An offence only counts as a repeat if it is established at least three months after the previous fined one.
FPS Finance applied no penalties for the new obligation from January to March 2026 for companies that could show they had taken steps in a timely and reasonable way, and ruled out a general postponement. For self-billing, it allowed flexibility until 30 June 2026 where the software provider was still building the function. Customers carry a risk too: deducting VAT on an in-scope purchase normally requires the structured invoice, with a substance-over-form exception when the material conditions are met.
What it costs
The government offers no free central application, and FPS Finance says that was a deliberate choice for a market-driven model. BOSA describes Hermes, its service that turned Peppol invoices into PDFs, as under review; several e-invoicing providers report it stopped at the end of 2025.
The FPS Finance list. FPS Finance publishes a list of compliant end-user software, last updated on 26 June 2026; in May 2025 it already counted more than 250 applications. Listing is not an endorsement and the list is not complete. Check that your choice both sends and receives.
Free or bundled. Compliance can cost nothing when it comes with accounting software or a bank package, FPS Finance notes. Odoo says its access point offers free, unlimited sending and receiving (what Odoo costs). Teamleader Focus sends Peppol invoices in every plan but receives them only from GROW up (Teamleader Focus pricing).
Tax support. For the 2024 to 2027 taxable periods, small SMEs and self-employed people can deduct 120% of invoicing subscriptions and related advice costs, if the e-invoicing surcharge is shown separately. The deduction for digital investments rose to 20% on 1 January 2025.
The next step: e-reporting from 2028
For now, no invoice data goes to the tax authority. FPS Finance's FAQ says near real-time reporting is in the federal coalition agreement for 2028 and will replace the annual customer listing. On 18 July 2026 the federal government approved a preliminary draft law setting the start at 1 January 2028, with both supplier and customer reporting, according to e-invoicing providers citing its summary. A preliminary draft is not yet law.
What it changes for B2B sellers
The enterprise number is the address. Because every Belgian company is reachable under 0208 plus its enterprise number, FPS Finance says you do not need to ask customers for their Peppol ID. The number in your customer record becomes the routing key. A wrong one sends the invoice to another company, which should reject it, and you then owe a credit note.
VAT status decides the format. Whether the customer is subject to VAT decides whether a structured invoice is compulsory.
A customer who cannot receive. You may then use another method, provided you agree on a secure alternative. That invoice is legally valid, your obligation is met, and the fine risk sits with the customer.
Master data flows downstream. If your CRM makes the quote and your accounting tool the invoice, the enterprise number must travel between them unchanged. The CRM comparison for Belgian SMEs shows which systems also handle Peppol.
If your CRM holds companies without an enterprise number, or with numbers nobody has checked, fix that before an invoice goes astray. Bizzy shows Belgian company data from the KBO register, including the enterprise number and VAT number, and connects to HubSpot, Salesforce, Pipedrive, Microsoft Dynamics 365, Teamleader Focus and Odoo, where you choose per field whether to fill empty values or overwrite existing ones. You can start for free.
Two documents that work differently under Peppol: credit notes and pro forma and advance invoices.
Frequently asked questions
Is Peppol mandatory in Belgium? Structured e-invoicing has been mandatory for almost all invoices between VAT-registered businesses established in Belgium since 1 January 2026, and Peppol is the default network. Another channel or format needs both parties' agreement and must meet the European standard.
Does a business under the small enterprise exemption scheme need Peppol? Yes. FPS Finance says the obligation applies to companies using the exemption scheme for turnover up to 25,000 euros a year.
What is the fine for not using Peppol? For lacking the means to send and receive structured invoices: 1,500 euros for a first offence, 3,000 euros for a second and 5,000 euros for each following one, on top of the existing invoicing fines.
Is there a free Peppol solution in Belgium? Not from the government. Some software includes Peppol at no extra cost, Odoo for example, and FPS Finance publishes a list of compliant applications without recommending any.
Photo: the belfry and cloth hall of Ghent seen from above, Michiel Hendryckx, CC BY 3.0, via Wikimedia Commons