Belgium - NL
The Royal Decree (RD) regarding mandatory e-invoicing has been published. Below we provide the main topics from this new RD. Remarkably, the legislator now also provides concrete fines for non-compliance with mandatory e-invoicing.
Although there were a lot of voices lately that the mandate could be delayed, it has now been confirmed that e-invoicing will become mandatory for all transactions between VAT-registered companies as of Jan. 1, 2026.
This measure is part of a broader digitization strategy and aims to reduce the administrative burden, speed up invoicing processes and better combat VAT fraud. Businesses would do well to prepare in time, as the move to e-invoicing often requires technical adjustments and a review of existing processes.
In Belgium, Peppol is becoming the standard for e-invoicing, both as a "network" and in terms of format (the so-called Peppol BIS format). Companies may deviate from this and choose another network or format for e-invoicing. In practice, these 'sector-specific formats', such as EDIFACT or ANSI X12, are only for large companies with a lot of incoming invoices.
Moreover, if these companies are subject to VAT, they are also required to be able to receive Peppol invoices. For the average Belgian SME, e-invoicing via Peppol will become the norm.
Compliance with the new e-invoicing rules is not optional. Companies that fail to comply risk significant, non-proportional fines.
The penalties are as follows:
A grace period of three months is applied between two violations. Only after the expiration of that period is a new violation considered a new violation, which determines the amount of the fine. It is therefore crucial that companies regulate themselves with the new e-invoicing obligations in a timely manner to avoid financial risks.
With the introduction of the new e-invoicing rules, the way VAT is rounded also changes. From now on, VAT may no longer be rounded per invoice line. Instead, rounding is done exclusively on the total amount of the invoice.
This change ensures more uniformity and accuracy in VAT calculation and is in line with the technical requirements of electronic invoicing formats such as Peppol BIS and UBL. Businesses should align their invoicing systems with this in a timely manner to avoid errors and possible rejection of invoices.
The full RD is available at this link
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