The obligation took effect on 1 January 2026 and the tolerance period has been over since April. For businesses that have not yet switched, the question is no longer whether they are concerned, but how to catch up. Here is the exact framework, the exclusions, and the calendar of deadlines that goes with it.
- Who is concerned, and who is not
- Why a PDF by email no longer suffices
- What you need in place
- Penalties and the end of tolerance
- The 2026 tax calendar
- What your accountant handles
- How long to keep invoices
- Common mistakes at the start
- What if my customer is not connected yet
Who is concerned, and who is not
The obligation covers businesses that are VAT-registered and established in Belgium, for the invoices they address to other taxable persons established in Belgium. That is the domestic B2B scope.
It applies whatever the number of invoices issued, and with no turnover threshold. Small businesses under the exemption scheme, with turnover of no more than 25 000 €, are therefore concerned, as are taxable persons under the agricultural scheme.
Outside the scope are:
- Taxable persons exempt under article 44 of the VAT Code because of the nature of their activity, which covers many medical and paramedical professions
- Foreign taxable persons without a fixed establishment in Belgium
- Bankrupt taxable persons, for issuing invoices
- Taxable persons under the flat-rate scheme of article 56 of the VAT Code, until 1 January 2028
B2G follows a separate regime: electronic invoicing has been mandatory there since 1 March 2024 for public contracts published after that date, with an exception below the threshold of 3 000 € excluding VAT. B2C and international transactions are not covered by the structured-format obligation.
Why a PDF by email no longer suffices
This is the point most businesses got wrong. A PDF is a picture of an invoice: a human reads it, software cannot reliably extract data from it.
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, a profile of the European standard on electronic invoicing.
Two businesses may agree on another format between themselves, provided it complies with that European standard. In practice Peppol is the default arrangement and the simplest route.
What you need in place
Three things, no more.
A tool able to issue in structured format. Most invoicing and accounting software active in Belgium integrated that function during 2025.
A connection to the network. You do not connect to Peppol directly: you go through an accredited access point, generally built into your software or supplied by a third-party service.
The ability to receive. This is the forgotten half of the obligation. A business that can issue but not receive blocks its suppliers and is exposed just as much as a business that has done nothing.
Each participant is identified on the network by their CBE enterprise number, which lets a sender check whether their customer is reachable before sending.
Penalties and the end of tolerance
The administration announced a soft-touch approach during the first three months of 2026, giving businesses time to connect. That tolerance period ended in April 2026: it can no longer be relied on.
The penalty regime provided for by the royal decree of 8 July 2025 rests on a progressive fixed fine for repeated breaches, with amounts reported by practitioners ranging from 1 500 € for a first breach to 5 000 € for subsequent ones. On top of that come the ordinary invoicing fines under article 70 of the VAT Code.
The real risk, however, is not primarily the fine. It is commercial blockage: a customer subject to the obligation cannot indefinitely accept your invoices in a non-compliant format.
The 2026 tax calendar
Electronic invoicing arrives in the same year as the modernisation of the VAT chain. Here are the deadlines that structure a Belgian company's year.
| Deadline | When | What |
|---|---|---|
| Monthly VAT return | The 20th of the following month | Filing and payment |
| Quarterly VAT return | The 25th of the month following the quarter | Filing and payment |
| Annual customer listing | 31 March | For the previous year |
| VAT provision account | Since 1 May 2026 | Replaces the VAT current account |
| General meeting for approval | Within 6 months of the close | Approval of the annual accounts |
| Filing of the annual accounts | 30 days after the meeting, and no later than 7 months after the close | Central Balance Sheet Office of the National Bank |
Since 1 May 2026, the VAT current account has given way to the VAT provision account. The summer tolerance regime was abolished, the administration may issue a substitute return where a periodic return is not filed, and the account number for payments has changed. That last point deserves a direct check on MyMinfin or with your accountant before any transfer: a VAT payment sent to the old account is an avoidable complication.
What your accountant handles
Connecting to the network and configuring the tool usually falls to the firm, or to the software publisher with the firm's support. Checking that your customers are actually reachable happens in practice, as you go.
What stays on your side is more mundane but just as blocking: having clean customer data, starting with correct enterprise numbers, and stopping sending PDFs alongside, which creates duplicates in the recipient's accounts.
If your current software is not connected, the comparison of accounting software in Belgium sets out the categories of solutions and how to verify compatibility before changing tools.
How long to keep invoices
Going electronic does not shorten archiving, it moves it.
Article 60 of the VAT Code, amended by the law of 20 November 2022, sets the retention period at ten years. The period runs from 1 January of the year following the invoice date. It applies to taxes that became due from 1 January 2023. Documents relating to buildings or land are kept for fifteen years.
The obligation covers copies of invoices issued and invoices received, as well as accounting books, contracts, purchase orders and payment documents. They must remain immediately accessible on request from the administration. Keeping them outside Belgium is only permitted if the administration can access them online without delay.
The practical consequence is simple: your Peppol access point is not an archiving service. Passing through the network does not relieve you of keeping your invoices for ten years in a system you control.
Common mistakes at the start
Sending both the electronic invoice and the PDF. That is the reassuring reflex, and it creates duplicates in your customer's accounts. Once the electronic channel is in place, it replaces the email, it is not added to it.
Approximate customer data. A wrong or missing CBE enterprise number prevents delivery. Cleaning up the customer file is often the real work, well before the technical choice.
Forgetting reception. Many businesses activated issuing and later discovered that their suppliers' invoices were arriving in a mailbox nobody checked.
Assuming the accountant handles it alone. The firm configures and supports, but you issue your invoices. If you invoice from a tool the firm does not know, connecting it is on you.
What if my customer is not connected yet
The network lets you check whether a recipient is reachable before sending. If your customer is not, when they should be, the situation is awkward but it does not put you at fault: you have done what the obligation requires of you.
The useful reflex is to raise it early and in writing, rather than quietly reverting to PDF. Since the tolerance period ended in April 2026, the argument of an adjustment period no longer holds, and the matter is settled faster when it is put plainly.
Sources
- efacture.belgium.be, official electronic invoicing portal, scope and exclusions
- Who electronic invoicing becomes mandatory for
- Royal decree of 8 July 2025 amending royal decrees no. 1, 8 and 44 on VAT, Belgian Official Gazette of 14 July 2025
- Law of 6 February 2024 introducing the structured electronic invoicing obligation
- Article 60 of the VAT Code, amended by the law of 20 November 2022, retention period raised to ten years (circular 2023/C/58)
Information verified on 29 August 2026. The exact amount of the fines and the VAT account number must be confirmed with the administration or with your accountant before any decision.
Further reading
- Which accounting software should you choose in Belgium in 2026?
- Peppol: how the network works
- Find a firm that handles the connection
This article is for information only. It does not replace the advice of a registered professional on your specific situation.