Self-billing in Belgium on Peppol
When the customer issues the invoice for the supplier: written agreement, who appears as seller and buyer, who sends on Peppol, and common pitfalls for Belgian SMEs.
Updated
- Belgium
Self-billing in Belgium means the customer draws up the invoice for the supplier, under a written agreement. Peppol only carries the file. Seller and buyer names stay the real parties; do not swap them to “make send work”.
What self-billing means
In self-billing, the customer draws up the invoice for goods or services received from the supplier, under a prior agreement. Peppol only carries the structured file. The commercial and VAT setup must already be clear.
This does not replace your agreement or accountant review. Ordinary document roles: Invoice, credit note, and quote.
- Self-billing
A written arrangement where the buyer prepares the invoice for the supplier’s supply. The supplier remains the seller on the document; the buyer remains the customer.
Agreement first
Belgian practice expects a written self-billing agreement before these invoices circulate. Align at least on:
| Topic | Why |
|---|---|
| Scope of goods or services | Avoid self-billing random purchases |
| Accept / dispute window | Supplier can reject a wrong self-bill |
| Invoice numbering | Who owns the number sequence |
| VAT treatment | Mentions and tax treatment match the supply |
| Peppol channel | Who sends, which IDs, who archives the original |
Without that agreement, a structured file from the buyer is a workaround, not controlled self-billing.
Who issues, who sends
| Question | Practical answer |
|---|---|
| Who prepares the invoice? | The customer (buyer), under the agreement |
| Who is the supplier on the invoice? | Still the real supplier of the goods or services |
| Who is the customer on the invoice? | Still the buyer who received the supply |
| Who may send on Peppol? | Often the buyer (or their provider), acting under the agreement |
Sending the file is not the same as being the supplier. Do not swap names to make a normal sales invoice "fit". That breaks VAT evidence and matching.
Practical workflow
- Sign or renew the self-billing agreement; store it with master data.
- Confirm both Peppol identities and who will send.
- Keep supplier and customer parties correct; include required legal mentions.
- Use your tool's self-billed invoice option, not a normal sales invoice labelled in a footnote.
- Give the supplier a clear accept/reject path (process email or buyer responses if you use them).
- Correct errors with a self-billed credit note pattern, not by editing a delivered invoice (credit notes on Peppol).
For in-scope domestic B2B under the 2026 obligation, self-billing still needs a valid structured document when Peppol is the exchange path.
Common pitfalls
- No written agreement
- Buyer listed as supplier because they clicked Send
- Normal invoice type used while calling the flow "self-billing"
- Supplier has no way to reject a wrong self-bill
- PDF-only archive of a structured self-bill
Worked example
Retailer North weekly receives bread from Bakkerij Zuid. Their self-billing agreement says North prepares the invoice, uses North’s self-bill series, and sends it on Peppol to Zuid’s receive ID. The invoice still names Bakkerij Zuid as supplier and North as customer. A wrong quantity is fixed with a self-billed credit note, not by editing last Tuesday’s delivered file.
FAQ
What is self-billing in Belgium?
The customer prepares the invoice for the supplier’s goods or services, under a prior written agreement. The real supplier stays the seller on the document.
Is self-billing the default B2B flow?
No. Most SMEs issue their own sales invoices. Use self-billing only when the contract says the customer prepares the invoice.
Who appears as supplier on a self-billed invoice?
The real supplier of the goods or services, not the party who clicked Send.
Does self-billing still use Peppol in 2026?
Yes when the exchange path is structured B2B. Peppol carries the file; the agreement still governs who prepares it.
How do you correct a wrong self-bill?
With a self-billed credit note (and a new self-bill if needed), not by editing a delivered invoice.
Is a footnote on a normal invoice enough?
No. Use the self-billed document type your tool documents. A normal invoice labelled “self-billing” breaks automation.