B2B vs B2C e-invoicing in Belgium: which channel for each customer

Whether an invoice must be a structured Peppol invoice depends on who the customer is and in what capacity it buys, never on the amount; a Belgian public authority follows separate B2G (business-to-government) rules.

This reference is the per-customer routing table, with the usual edge cases and the OrdoGrid steps. Your own status (small business exemption, flat-rate, exempt, foreign) and the legal background are in the 2026 obligation reference.

The test: one question per customer and per purchase

Since 1 January 2026, art. 53 §2bis of the VAT Code requires a structured electronic invoice when all four conditions hold:

1. You are a taxable person established in Belgium, invoicing under your Belgian VAT number, and neither under the flat-rate regime of art. 56 nor bankrupt (for the activity covered by the bankruptcy).
2. The supply is not exempt under art. 44 VAT Code (certain medical, educational, social and financial services).
3. The customer is a taxable person established in Belgium that must give you its Belgian VAT number for this purchase, or a VAT unit.
4. The invoice, advance-payment invoices included, is issued from 1 January 2026.

Condition 3 decides the channel, and it is tested per purchase: a self-employed person buying for the business is a business customer, and a consumer when buying privately. There is no amount threshold: a simplified invoice of €100 or less excluding VAT is structured too when in scope (FPS Finance FAQ on specific questions, Q18). The default format is Peppol BIS (UBL) over the Peppol network (art. 13ter Royal Decree no. 1); another EN 16931 format needs an agreement, and a PDF never qualifies.

Established in Belgium

Having the seat of its economic activity or a fixed establishment in Belgium. Since the Law of 10 February 2026, a Belgian VAT number alone does not prove it: a foreign business can hold one without being established here, and is then outside the obligation both ways.

Routing table: which channel for which customer

“Peppol if registered” is voluntary use: outside the obligation a structured invoice needs the recipient's agreement, and FPS Finance treats registration on Peppol as that agreement (FAQ B2B, Q9).

Fallback. If a customer that should receive structured invoices cannot technically receive them, you still issue an ordinary invoice on paper or as a PDF (art. 53 §2bis, sixth paragraph). It is valid; the customer stays in breach of its own duty to receive. Steps: client not on Peppol.

Consumers: when do you owe an invoice at all?

The structured obligation does not cover private individuals (FPS FAQ specific, Q15). Ordinary VAT law requires an invoice to a private individual only for the operations listed in art. 1 of Royal Decree no. 1, for example:

• new or used vehicles, boats and aircraft;
• new buildings, building work and other work on immovable property;
• vehicle parts and repairs above €125 including VAT;
• removals and hire-purchase;
• investment gold above €2,500.

An advance payment on such an operation also triggers the invoice. For other consumer sales no VAT invoice is required, though you may issue one. A consumer invoice shows the customer's name and address, without a VAT number. Sending it as a PDF by email needs the customer's agreement; otherwise give it on paper.

Public authorities: B2G rules, not B2B

Invoicing a Belgian contracting authority follows the Royal Decree of 9 March 2022, as amended in 2023. According to FPS Finance, e-invoices are compulsory for public contracts published since 1 March 2024, in principle from €3,000 excluding VAT; larger contracts were covered earlier. An authority may be stricter in its tender documents, and federal contracting authorities also require e-invoices below €3,000.

1. Check the authority in the KBO/BCE (Crossroads Bank for Enterprises): a B2G customer shows the capacity “Contracting authority” with a start date.
2. Find the reference to quote in the contract or order. Peppol BIS also requires a buyer reference or an order reference on every invoice (rule PEPPOL-EN16931-R003).
3. Send on Peppol to the authority's enterprise number. Mercurius, run by FPS BOSA, is the public sector's mailroom: it receives over Peppol and passes invoices on.
4. Without Peppol software, invoices can be entered on the Mercurius portal with an eID. BOSA announced a new Mercurius platform for the end of 2026: check BOSA's page before relying on portal details.

FPS Finance has not said whether a VAT-registered public body is also a B2B recipient; a Peppol invoice satisfies both rules. More: Mercurius and B2G invoicing.

Mixed businesses: one policy for counter, workshop and office

Our recommendations for businesses with private and business customers:

• Ask at order intake: “Is this for your business? What is your VAT number?” Record the answer on the client before invoicing.
• Route by customer type, not account size. “Peppol for large accounts, PDF for the rest” leaves in-scope invoices non-compliant.
• Do not ask for a Peppol ID. Every Belgian participant must be registered at least under 0208: plus its enterprise number, and FPS Finance advises against asking customers for one (FAQ B2B, Q15).
• Credit notes follow the original. A credit note correcting a structured invoice must be structured; one correcting a consumer PDF can stay a PDF.

Receiving: required even if you sell only to consumers

Your customers decide how you send, not whether you must receive. A business selling only to consumers but buying from Belgian suppliers must be able to receive structured invoices (FPS Finance, 7 April 2026). Among Belgian-established businesses that buy from Belgian suppliers, only those making exclusively art. 44-exempt supplies are exempt from receiving.

In OrdoGrid: client records decide the proposed channel

What OrdoGrid does. At send time it looks up the client's N° de TVA (VAT number) on Peppol and ticks Peppol only if the client is found. The client type alone routes nothing, and OrdoGrid does not check whether a client is established in Belgium or buys privately: those decisions stay with you.

Set up each client

1. Open Clients in the sidebar (page Base Clients) and click Ajouter un client (add a client), or edit an existing one.
2. Choose Type de client (client type): Particulier (private individual) for consumers, Assujetti à la TVA (VAT-registered) for businesses. Use Assujetti à la TVA for any organisation too: only this type has a company-name field.
3. For a business, enter its N° de TVA. OrdoGrid shows the register data with its source, Registre belge (BCE) or VIES (UE); click Pré-remplir (prefill) to copy the name and address into the client record. A BE number with a foreign address calls for the establishment check.
4. For an association or public body without a VAT number, leave N° de TVA empty: OrdoGrid then sends a PDF only, as it has no separate enterprise-number field. Entering BE plus the enterprise number would reach the body on Peppol, but OrdoGrid then prints that number on the PDF as a VAT number and sends it as the buyer's VAT number in the Peppol XML, although the body has none. Agree on this with the buyer first or, for a public buyer, use the Mercurius portal.
5. For a public buyer that issues order numbers, tick Exiger un bon de commande pour les factures (require a purchase order). The editor then asks for the N° bon de commande, sent as the Peppol buyer reference.

Send each invoice

1. Create the invoice with Nouvelle facture (new invoice), select the client and add the lines.
2. Click Envoyer (send). The popover checks the client:

3. Click Sauvegarder & Envoyer (save and send). OrdoGrid never switches to email by itself when Peppol is skipped: make sure Email is ticked.
4. Follow Peppol sends in Peppol → Outbox. Traité means delivered on the network, not accepted or paid.

Full walkthrough: first Peppol invoice.

Counter sales and receiving

Reçus (receipts) record payments already received; they are not invoices and never go on Peppol. When a business customer needs an invoice, use Facturer (invoice) on the receipt, then send the invoice as above. Receipts of clients without a VAT number can be grouped into one invoice; those of VAT-registered clients each need their own, which OrdoGrid flags with Reçus avec n° de TVA.

To receive, click Activer la réception (activate receiving) in the Mode : Envoi seul (send-only mode) banner on the Peppol page; on the Réception Peppol page that opens, click Activer la réception again: OrdoGrid registers you under 0208: plus your enterprise number. If another provider already receives for you, choose Continuer en envoi seul (send-only). Supplier invoices arrive in Peppol → Inbox.

Worked example: Garage Mertens SRL, week of 28 September 2026

Garage Mertens SRL repairs cars in Wavre under the normal VAT regime, at 21%, and sends and receives through OrdoGrid.

• Ms Lambert: her brake repair costs more than €125 including VAT, so an invoice is required (art. 1 RD no. 1), but not a structured one. Client type Particulier; the popover shows Pas de numéro de TVA client; she agreed to invoices by email.
• Bureau Verlinden SRL is found on Peppol. The garage unticks Email, and the Outbox later shows Traité.
• Tom Lejeune uses the small business exemption but buys for his business van: in scope. The popover shows Le client n'est pas enregistré sur le réseau Peppol, and lookup.peppol.org finds nothing under 0208: plus his enterprise number. The garage applies the fallback (PDF by email, with his agreement), keeps a dated screenshot of the lookup and tells him he must be able to receive. Later invoices go on Peppol once he is registered; F-2026-0313 is not resent.
• Commune de Mont-Saint-Rémy awarded a fleet-maintenance contract published in 2025, above €3,000 excluding VAT, so B2G e-invoicing applies. The commune is VAT-registered; its client record holds its VAT number (BE plus its enterprise number) and requires a purchase order; the garage enters BC-2026-0318 in N° bon de commande and the invoice reaches the commune over Peppol through Mercurius.
• Patro Saint-Joseph ASBL has no VAT number: owed an invoice as a legal person, not a structured one. Set up as Assujetti à la TVA with an empty N° de TVA, it receives a PDF.
• Autoparts Wallonie SA must send structured. Its invoice lands in Peppol → Inbox, where the garage checks it against the delivery note before paying.

Check: sales total €12,800.00 excluding VAT plus €2,688.00 VAT (exactly 21%), €15,488.00 in all. Two invoices worth €13,068.00 went on Peppol and three worth €2,420.00 as PDFs, each issued on the repair day, well before the 15th of the following month (art. 4 RD no. 1).

Edge cases and common mistakes

Evidence to keep

What the law requires. Keep issued invoices and credit notes, whatever the channel, for seven years from 1 January of the year after issue (art. 60 VAT Code, as amended by the Law of 18 December 2025), with authenticity, integrity and legibility guaranteed.

What we recommend. Keep the basis of each routing decision: the client's VAT or enterprise number with the register shown and the date checked; the customer's written statement when its capacity or establishment is unclear; the Peppol lookup result and the message you sent the customer with each fallback invoice; the contract or order of each public buyer; and each consumer's agreement to invoices by email.

What OrdoGrid does. It archives the exact XML and PDF of every Peppol send, downloadable from Peppol → Outbox, and shows each invoice's email and Peppol history under Envoi et Paiement. It is not a legal archive and guarantees no retention period: file these documents in your own archive.

FAQ

Is Peppol required for invoices to consumers in Belgium?

No. The structured obligation covers supplies, other than art. 44-exempt ones, between taxable persons established in Belgium. A consumer invoice goes as a PDF, with the customer's agreement, or on paper.

Must I give a private customer an invoice at all?

Only for the operations listed in art. 1 of Royal Decree no. 1, such as vehicle sales, building work and vehicle repairs above €125 including VAT. Otherwise no VAT invoice is required, though you may issue one.

My customer is a sole trader. Is that B2B or B2C?

It depends on the purchase. If it buys for the business with its Belgian VAT number, the sale is B2B and needs a structured invoice, even under the small business exemption. If it buys privately, it is a consumer.

Does an ASBL count as a business customer?

Only when it is VAT-registered and buys for its taxable activity. An association without a VAT number is owed an invoice as a legal person, but not a structured one, unless it is registered on Peppol and you choose to send there.

How do I invoice a commune or another public body?

Under the B2G rules: e-invoices are compulsory for contracts published since 1 March 2024, in principle from €3,000 excluding VAT, and federal authorities require them below that too. Send on Peppol to the authority's enterprise number and quote its order reference.

My customer gave me its VAT number after I invoiced it as a private person. What now?

We recommend a full credit note for the first invoice, sent like the original. Then switch the client's Type de client to Assujetti à la TVA, enter its N° de TVA and issue a new invoice on Peppol. Check the approach with your accountant.

Can I send the same invoice by Peppol and by email?

It is not forbidden, and OrdoGrid lets you tick both. The Peppol invoice is the legal one; Belgian Peppol providers recommend avoiding dual sending when the customer receives on Peppol, so email a copy only on request.

I only sell to consumers. Do I need Peppol?

Not for sending, but you must be able to receive structured invoices from your Belgian suppliers, unless you make only art. 44-exempt supplies.