Mandatory structured VAT e-invoicing for B2B supplies in Belgium as of 1 January 2026

A Law of 6 February 2024 has introduced the obligation for taxable persons established in Belgium (including VAT groups) and foreign entities with a fixed establishment in Belgium to issue and receive structured e-invoices for non-exempt ‘domestic’ B2B transactions as of 1 January 2026.

Contrary to initial proposals that were circulating last year, the adopted legislation has gone down the route of a “big bang” rather than a phased implementation of e-invoicing depending on the annual turnover of the taxable person.

PDF-files and hyperlinks shared by email will not qualify as structured e-invoices. The Peppol-BIS standard must in principle be used instead. This will allow the use of the existing European PEPPOL network for the electronic exchange of the e-invoices.

The aim of the new legislation is to achieve administrative simplification, as well as to combat fraud and errors in VAT reporting and payment. It is intended to serve as a future basis for electronic reporting systems, allowing earlier and more efficient verification of VAT compliance. The new rules are therefore expected to be further modified and completed in the future, also depending on relevant developments at EU level (e.g. VAT in the Digital Age proposals).

Key takeaway

Taxable persons will often require outside assistance in order to implement the new invoicing rules by 2026. Given their critical importance, agreements to this end with external providers will need to be reviewed by both technology lawyers and tax specialists. Alongside this, impacted taxable persons should already consider whether any changes are needed to their tax governance and operating model to avoid getting caught out when real-time reporting is layered on to the structured e-invoicing. Belgium has the EU VAT presidency currently and with ViDA high on the agenda, and e-invoicing a very significant part of the proposals, this space should be watched carefully.

Reference: Parlementair Document 55K3743