E-invoicing back on the Belgian political agenda – Plan to introduce B2B mandate on 1 January 2026

The Belgian finance minister has relaunched a legislative proposal to introduce mandatory e-invoicing for domestic business-to-business (B2B) transactions. A draft legislative proposal was adopted by the Council of Ministers on 29 September 2023, which aims to implement the e-invoicing obligation on 1 January 2026. To bring this legislative proposal to adoption, the government will need to obtain a derogation from the European Commission and pass the legislation through parliament.

Previous proposal

Two important differences as compared to the previous e-invoicing proposal (which was part of the finance minister’s  tax reform measures) are:

1. There is no phased implementation, i.e., the mandate would become applicable to all Belgian established VAT registered entities as from 1 January 2026;and
2. An associated e-reporting obligation is expected to be defined and introduced at a later stage.

B2B e-invoicing

In summary, the B2B e-invoicing mandate would:

• Apply to taxable persons established in Belgium and Belgian branches of foreign entities (foreign businesses with a mere VAT registration in Belgium are not envisaged at the moment); andOblige companies to issue invoices in an electronic structured data format (PEPPOL-BIS) for domestic transactions in Belgium.

• Parties would be able to agree to use another structured data format as long as it is in line with the European EN16931 standard. Sending a pdf invoice per e-mail would hence no longer be allowed in a domestic B2B context.

Comments

Despite the seemingly distant "big bang" implementation deadline, businesses should begin preparing for this potential new mandate as soon as possible. Businesses can leverage the e-invoicing obligation as an opportunity to reassess their digital strategy for the future and begin exploring solutions that are tailored to their company's unique requirements. The introduction of e-invoicing could serve as a catalyst for the transformation and automation of business’ tax and finance processes.

As always, our committed team of experts is ready to assist you in navigating upcoming changes, addressing challenges, and seizing new opportunities. We are more than happy to provide you with comprehensive insights through our meticulously designed end-to-end e-invoicing journey. Furthermore, we are eager to explain how our integrated data solution could connect the e-invoicing and e-reporting dots and seamlessly integrate into your evolving enterprise resource planning (ERP) architectural landscape

.If you would be interested in learning more about our tailored service offerings in this regard, please do not hesitate to reach out to us.