Grace period but no general postponement of the Belgian e-invoicing mandate

On 2 December 2025 (Dutch/French), the administration has announced a grace period for the first three months of 2026 in relation to the upcoming Belgian e-invoicing obligation. This tolerance only applies if the taxpayer can demonstrate that timely and reasonable efforts have been made to comply with the Belgian e-invoicing mandate.

For more information about the upcoming Belgian e-invoicing effective from 1 January 2026, we kindly refer to our previous Tax Alerts:

• Mandatory B2B e-invoicing published in the Belgian Official Journal - entry into force 1 January 2026,

• Non-established entities excluded from the Belgian B2B e-invoicing mandate,

• Royal Decree on the Belgian e-invoicing mandate published,

• FAQs on Belgian e-invoicing requirements updated

Scope of the tolerance

Infractions specific to the e-invoicing obligation

The tolerance will only apply to infractions specific to the new obligation including:

• Businesses still lacking the technical capability to send and/or receive a structured electronic invoice (in general or for certain transactions)

• Businesses unable to issue structured electronic invoices because its own system or the system of a third party they rely on, does not yet allow issuing a valid electronic invoice (in general or for certain transactions).

During the grace period, businesses must still comply with invoicing obligations by using an alternative format (e.g. PDF) or an alternative method of sending (e.g. e-mail).

‘Timely and reasonable’ efforts

The tolerance only applies if businesses can prove that sufficient efforts have been made for the timely and correct implementation of e-invoicing in their ERP and billing systems.

These businesses have the opportunity to regularise their situation without being sanctioned during the first three months of 2026.

The authorities do not provide further guidance on what is considered as ‘timely and reasonable’ efforts but mention that this will be evaluated on a case-by-case basis depending on the concrete circumstances.

No general postponement

The deadline of 1 January 2026 remains unchanged, as a postponement would be unfair to companies that prepared on time.

More than half a million companies have already prepared for the upcoming e-invoicing obligation and many businesses are currently finalising their preparations.

If your business is not (fully) prepared yet, please feel free to contact us, we are happy to support.