A PDF invoice is not an electronic invoice
This is the most widespread misunderstanding. A PDF sent by email remains a picture of an invoice: a human reads it, software cannot. An electronic invoice in the legal sense is a structured file in which every piece of data is identified and directly usable by the recipient's accounting system.
In Belgium the chosen format is Peppol BIS, carried over the Peppol network. Two businesses may agree on another format provided it complies with the European standard, but Peppol is the default arrangement.
Who is affected
The obligation covers businesses that are VAT-registered and established in Belgium, for invoices addressed to other Belgian taxable persons. It also applies to small businesses under the exemption scheme, with turnover of no more than 25 000 €.
Outside the scope are taxable persons exempt under article 44 of the VAT Code, such as many medical professions, foreign taxable persons without a fixed establishment in Belgium, bankrupt taxable persons for issuing, and taxable persons under the flat-rate scheme of article 56 until 1 January 2028.
What it involves
In practice you need software or a service able to issue and receive over Peppol, plus registration on the network. Receiving counts as much as issuing: a business that cannot receive blocks its suppliers and remains in breach.
The administration allowed a soft-touch approach during the first three months of 2026. That tolerance period ended in April 2026 and can no longer be relied on.
Retention stays at ten years
Going electronic does not shorten archiving. Article 60 of the VAT Code, amended by the law of 20 November 2022, sets the retention period at ten years, counted from 1 January of the year following the invoice date. Documents relating to buildings or land are kept for fifteen years.
A Peppol access point is not an archiving service: passing through the network does not relieve you of keeping your invoices in a system you control.
What people often confuse
Many businesses activated issuing and kept sending the PDF alongside, out of caution. That creates duplicates in the recipient's accounts. Once the electronic channel is in place it replaces the email, it is not added to it.
Our guide covers the electronic invoicing obligation and the 2026 calendar, and the comparison of Belgian accounting software helps you check whether your tool is compatible.