On 14 July 2025, the Royal Decree concerning the Belgian e-invoicing mandate was officially published in the Belgian Official Journal (Dutch/French).
This decree sets forth the standards for semantics, syntax, and transmission method related to the mandatory e-invoicing requirement in Belgium. It also introduces a new penalty and confirms the effective date of the Belgian e-invoicing mandate as 1 January 2026.
All structured electronic invoices must adhere to the European semantic and syntactic standard (EN16931). The Peppol BIS in the UBL format and the Peppol network as the transmission mechanism are established as the default electronic exchange framework. Consequently, all taxpayers subject to the Belgian e-invoicing mandate will be required to possess the technical capabilities to issue and receive Peppol BIS e-invoices via the Peppol network.
However, with mutual agreement between the involved parties, structured electronic invoices may be issued in formats other than Peppol BIS and transmitted through alternative digital means, provided that the format complies with the European standard for electronic invoicing.
Preparing for e-reporting
The Royal Decree confirms that the Peppol network will likely serve as the backbone for future near real-time digital reporting, which is expected to launch in 2028 for domestic transactions.
An important change that may significantly impact businesses currently calculating VAT at the line item level in their ERP or billing software pertains to rounding. Effective from 1 January 2026, and limited to e-invoices, rounding will only be permitted on the total amount per VAT rate, and no longer on a per line item basis.
In addition to existing penalties for non-compliance with invoicing rules, such as failing to issue invoices on time, a new non-proportional penalty is introduced for failing to meet the obligation to possess the technical means to send and receive Peppol BIS e-invoices via the Peppol network. The fines are structured as follows:
Businesses will be granted a three-month grace period to rectify their systems before a new penalty can be imposed by the tax authorities.
While it has been evident for some time that Belgium would adopt Peppol (BIS) as the standard for the upcoming e-invoicing mandate, it is helpful that this has now also been formally confirmed in legislation.
Businesses currently implementing rounding at line item level in their billing systems must assess the impact of the requirement to round on the total amount.
If preparations for the mandate have not yet started in your organisation, timing is crucial, as 1 January 2026 has been reaffirmed as the start date for the Belgian e-invoicing mandate.
Our team is prepared to assist you throughout your e-invoicing journey with our e-invoicing launch line. More information can be accessed via this link.