The Chamber has approved the draft law on mandatory structured electronic invoices between parties liable for VAT (hereinafter ‘B2B’). It is scheduled to enter into force on 1 January 2026 but is still subject to the approval of the Council of the European Union.
What exactly does this entail?
If the Council of the European Union gives the green light, as of 1 January 2026 electronic invoices will have to be prepared, issued and received in a structured format, and these invoices will also be processed automatically and electronically, without the need for manual intervention. Sending PDF invoices via e-mail, which we often see today, is therefore not covered by this.
How is this done?
The direct exchange and automatic processing of invoice data is made possible by the PEPPOL network, which is an international agreement framework concerning the format and exchange of electronic invoices. This system is already used in several EU Member States. In Belgium too, PEPPOL is already used for electronic invoices in a B2G context.
In concrete terms: company A connects to a PEPPOL Access Point via its invoicing/accounting package. Via that Access Point, the electronic invoice is forwarded to the PEPPOL Access Point to which the customer, company B, is connected. The electronic invoice is then loaded fully automatically into the software package of company B. Does PEPPOL still sound like an abstract concept? Don’t worry, today most ERP/accounting packages are already tailored to the technical requirements of the PEPPOL network, making connection easy.
To whom is it applicable?
The draft law has a threefold scope:
- Issuer of electronic invoice = all parties liable for VAT established in Belgium (not: those under a flat-rate scheme other than the agricultural scheme, the bankrupt and those who only carry out VAT-exempt operations cf. Art. 44 VAT Code)
- Recipient of electronic invoice = all parties liable for VAT who have to declare their VAT number, regardless of whether they are established in Belgium or not (not: those who only carry out VAT-exempt operations cf. Art. 44 VAT Code)
- Type of transaction = the supply of goods and services which are deemed to take place in Belgium (not: VAT-exempt supplies cf. Art. 44 VAT Code and VAT-exempt intracommunity supplies). In principle, only “local” transactions are covered. Transactions in which the purchaser must communicate their Belgian VAT number are also covered.
As of 1 January 2026, electronic invoices covered by these conditions must therefore be exchanged and processed via PEPPOL. For customers who are not yet ready to receive electronic invoices via PEPPOL, there is the option of using a platform such as Hermes, which converts structured electronic invoices into a PDF file.
It is crucial to be well prepared for this digitisation. In order to accommodate companies in this regard, a temporary cost deduction of 120% is provided for in income tax.
Our PKF BOFIDI experts will be pleased to give you further advice
Do you have any questions about the impact of electronic invoicing on your business or do you want to know how best to approach the changeover? If so, please do not hesitate to contact us. We are ready to help you with this transition.
This article was written by VAT expert Gladys Cristiaensen.