Belgium’s New PEPPOL E‑Invoicing Obligations: What You Need to Know Before 1 January 2026

From 1 January 2026, companies operating in Belgium will have to be able to receive electronic invoices via the PEPPOL network. This new obligation applies to invoices and credit notes, but not to documents such as offers or timesheets. 

The new rules are wide‑ranging. The obligation to receive invoices through PEPPOL applies to Belgian businesses (both corporations and self-employed persons) that are required to account for VAT, and to those benefiting from VAT exemptions such as the small‑enterprise regimes (“BTW‑vrijstelling” / “Exonération de TVA”). By contrast, the obligation does not apply to undertakings whose activities are exempt from VAT under Article 44 of the Belgian VAT Code, for example medical practitioners and educational institutions (although only if they exclusively exercise such activities. A doctor who also provides medical reports as an expert will fall under the e-invoicing rules).

The reform therefore affects a broad swathe of the Belgian economy, from traditional VAT‑liable companies to very small operators.

Important to note is that the obligation to issue e-invoices through the PEPPOL network only applies between Belgian companies. Consumers or foreign companies are by definition excluded. It is however not prohibited to agree with a foreign supplier or customer to use PEPPOL e-invoicing in the business relationship too. Large Belgian companies may be expected to contractually require such invoicing procedures to apply to foreign suppliers to simplify their administration.

Good to note: no more changes of invoices through Word, Excel or otherwise as of now (which was anyhow prohibited). Once an invoice is sent electronically, it can no longer be altered and a credit note is required, followed by a new invoice (both to be sent through PEPPOL).

The sanctions for ignoring the new framework are significant. A business that does not use PEPPOL correctly (both as a sender and/or a receiver) will first receive a warning and enjoy a three‑month transitional period for a first infringement, insofar it can be demonstrated that efforts to implement PEPPOL within the company have been made. Beyond that grace period, the consequences become much more severe. An invoice sent or received outside PEPPOL when the obligation applies is treated as a “non‑existent invoice”, with the result that VAT can no longer be deducted. Each violation can trigger administrative fines: EUR 1,500 for the first offence, EUR 3,000 for the second, and EUR 5,000 for the third and subsequent offences. The financial and tax stakes are therefore substantial.

Businesses also need to decide how to respond to invoices that are sent outside PEPPOL by a Belgian supplier once the rules enter into force as of the 1st of January 2026. The recommendation is to react to any such invoice – for example one sent by email – as soon as possible and using the same channel, thereby rejecting the invoice explicitly if it should have been issued through PEPPOL.

How protests are made is equally important. Remember: words fly away, written ones remain. Only written records of a specific protest of a non-PEPPOL invoice will later serve as evidence. 

Clear internal rules should be put in place with the accountant on how to process the invoices and credit notes received and under what circumstances they will be refused or regularised. After all, invoices will now in principle appear in a digital inbox in the chosen e-invoicing program first. Some tools may allow for a copy to be sent by email too (which cannot be regarded as an official invoice when sent outside the PEPPOL network only). At the same time, suppliers should remember that receiving an invoice via PEPPOL does not in itself mean that the invoice has been accepted by their client.

The PEPPOL system itself will not take over the task of chasing unpaid invoices. It does not send reminders for overdue payments, so companies will have to continue issuing reminders themselves or configure their invoicing software to do so automatically. 

Alongside the obligations, there is a tangible tax incentive to ease the transition. To encourage companies to adopt PEPPOL, Belgium allows an increased deduction of income‑earning expenses: 120% of certain costs can be deducted, specifically the cost of e‑invoicing software packages and the cost of professional advice on implementing e‑invoicing. This support is, for now, available until 1 January 2028. 

Should you have any further questions regarding e-invoicing in Belgium, feel free to reach out to Allegiance Law at: info@allegiance.law.