Belgian B2B e-invoicing obligation 2026: who must send and receive

Since 1 January 2026, a business established in Belgium must issue a structured electronic invoice to its Belgian business customers and must be able to receive one from its Belgian suppliers. The default is Peppol BIS over the Peppol network. For these flows a PDF sent by email is no longer the invoice.

This reference covers the legal rule, who is in and out, which documents count and what to do when a counterparty cannot receive. Per-invoice routing is in B2B vs B2C e-invoicing in Belgium, the status of PDFs in PDF or structured invoice in Belgium, and fines in penalties.

What the law requires since 1 January 2026

Structured electronic invoice

An invoice issued, transmitted and received in a structured electronic form that allows automatic processing (Law of 6 February 2024). A PDF, scan or Word file is not one, even when signed.

Legal basis and timeline

The rule comes from the Law of 6 February 2024, the Royal Decree of 8 July 2025 (format, capability, fines), the Royal Decree of 17 December 2025 (credit notes, deduction, rounding) and the Law of 10 February 2026, explained in FPS Finance circular 2026/C/43.

Does this invoice have to be structured? Four questions

Answer per customer, not once for your whole business:

1. Are you established in Belgium and invoicing under your Belgian VAT number? If not, the Belgian obligation does not apply to you.
2. Is the customer a taxable person established in Belgium that gives its Belgian VAT number, or a VAT unit? A private person, a foreign business or a body that is not a taxable person is outside.
3. Is the supply exempt under art. 44? Supplies exempt under art. 44 VAT Code (certain medical, educational and social services, for example) are outside. Small business exemption (franchise) supplies are not art. 44 exemptions: they are inside.
4. Is it an invoice issued from 1 January 2026, including an advance-payment invoice or a credit note correcting a structured invoice?

Four yeses: issue a structured invoice. There is no amount or turnover threshold: a €40 invoice to a Belgian company is covered like a €40,000 one.

Who is in and who is out

Your own status

Your customer, when you are in scope

A business that sells only to consumers but buys from Belgian businesses must still be able to receive.

Which documents are covered

Details: FPS Finance FAQ on specific questions.

When a Belgian customer cannot receive

The fallback rule (art. 53 §2bis, sixth paragraph, applied since 1 January 2026): if the recipient cannot technically receive, itself or through a provider, you need not issue a structured invoice, but must still issue an ordinary one on paper or as a PDF. It is legally valid and deductible if complete. The customer remains in breach of its own duty to receive.

1. Check the customer on lookup.peppol.org, as FPS Finance advises: 0208: followed by its ten-digit enterprise number. A hit shows it can receive, not whether it can send.
2. No hit: check the VAT number you hold and ask the customer which provider receives for it.
3. Still unreachable: send a PDF by email if the customer accepts electronic invoices, otherwise paper.
4. Keep proof of the check and of your message.
5. Once the customer can receive, send new invoices on Peppol. Never resend earlier ones as structured invoices.

Related cases:

• You are not ready. You risk the fine; the customer may refuse your invoice; if it accepts an invoice in another form, it keeps its VAT deduction.
• The customer imposes its portal. It cannot do so without your clear written consent (FPS Finance B2B FAQ, question 18).
• You agree another structured format (an EDI link, for example): allowed if it meets EN 16931 and is agreed, preferably in writing. You must still be able to use Peppol BIS. A PDF is not such a format.

More: client not on Peppol.

Fines, VAT deduction and misaddressed invoices

• Fines. No technical means to issue and receive: €1,500 for a first infringement, €3,000 for a second, €5,000 for each further one (Royal Decree no. 44, annex, section 2, heading I, point C). A second infringement counts only if established at least three months after the previous fined one. Supplier and customer can both be fined, and ordinary invoicing fines still apply: penalties.
• VAT deduction. In principle based on the structured invoice, but under the substance-over-form principle the wrong format can lead to a fine without by itself removing the deduction on a complete invoice.
• Invoice not meant for you. Do not book or deduct it; reject it with an Invoice Response, status RE. Peppol does not detect duplicates: your own checks must catch them.

Tax incentive: 120% deduction of e-invoicing costs

Small companies and self-employed natural persons can deduct 120% of their structured e-invoicing costs for taxable periods 2024 to 2027 (art. 64ter Income Tax Code 1992): software subscriptions, implementation advice and a separately invoiced e-invoicing surcharge, but not depreciation. Your accountant claims it (FPS Finance).

How OrdoGrid covers sending and receiving

What OrdoGrid does. OrdoGrid connects to Peppol through a certified access point. It sends invoices and credit notes on Peppol for companies with a BE VAT number, checks each file against EN 16931 and Peppol BIS Billing 3.0 before delivery, and can register you to receive under 0208: plus your enterprise number, the identifier FPS Finance requires.

What it does not decide. It finds customers on Peppol from their VAT number when you send, but does not check whether a customer is established in Belgium. It does not fall back to email automatically, does not issue self-billed invoices and does not book purchase invoices.

1. In Profil entreprise (company profile; only owners and administrators can edit it), enter your BE VAT number in Numéro de TVA (Optionnel) (VAT number, optional).
2. Open Peppol and sign the Autorisation Peppol (Peppol authorisation): a typed name and a checkbox, not a qualified electronic signature.
3. On Réception Peppol, click Activer la réception (activate receiving). If it shows Déjà inscrit sur le réseau Peppol, another provider receives for you: choose Continuer en envoi seul (send-only), which is compliant as long as that provider really receives.
4. For each invoice, click Envoyer (Send): when the customer is found, Envoi électronique via Peppol (send electronically via Peppol) is ticked. The Email box is also pre-ticked whenever the customer has an email address: untick it unless the customer asked for a PDF copy, because Belgian Peppol providers advise against dual sending. Then click Sauvegarder & Envoyer (Save & Send). Peppol — ignoré (Peppol — skipped) with Le client n'est pas enregistré sur le réseau Peppol (the customer is not registered on the Peppol network) means: apply the fallback. Keep Email ticked in the same window to send the PDF if the customer accepts electronic invoices, or post a paper invoice. Full steps: first Peppol invoice.
5. Received invoices appear in Peppol → Inbox. Répondre (reply) sends an Invoice Response, such as RE Rejetée with a reason code: receive supplier invoices.

Only one provider can receive for you per document type, and OrdoGrid does not support migration keys: your old provider must deregister you first (set up Peppol in OrdoGrid).

Worked example: one week at Atelier Nord SRL

Atelier Nord SRL, a joinery workshop established in Anderlecht under the normal VAT regime, handles five documents in the week of 5 October 2026, all at 21%. The two sales to businesses are supplies of goods without installation that stay in Belgium: Studio Berg collects its made-to-measure panels at the workshop, and Lumen's display cabinets are delivered to an address in Belgium. If Atelier Nord fitted them in the building of a customer that files periodic VAT returns, the work would fall under the co-contractor reverse charge (art. 20 Royal Decree no. 1) and the invoice would show no VAT.

• Studio Berg BV is established in Belgium: Atelier Nord unticks Email, the invoice goes on Peppol only and the Outbox shows Traité (network delivery, not acceptance). Two panels are damaged, so Atelier Nord selects F-2026-0142 in Factures (Invoices) and clicks Note de crédit (credit note). The credit note corrects a structured invoice, so it also goes on Peppol. Studio Berg now owes €4,840.00 − €484.00 = €4,356.00.
• Ms Claes is a consumer. Renovation work on her home requires an invoice (art. 1 Royal Decree no. 1), but not a structured one; OrdoGrid shows Pas de numéro de TVA client (no customer VAT number). The 21% rate keeps the example simple: reduced rates for housing work depend on conditions not covered here.
• Lumen SAS holds a Belgian VAT number but confirmed in writing that it has no seat or fixed establishment in Belgium, so neither party is bound. It is registered on Peppol under its Belgian enterprise number, which counts as agreement, so Atelier Nord sends the invoice there anyway.
• Houthandel Vermeulen BV must send structured and Atelier Nord must receive: the invoice arrives in Peppol → Inbox and is checked against the delivery note before payment.

Check: net sales after the credit note total €9,100.00 and the VAT of €1,911.00 is exactly 21% of that.

Common mistakes

Evidence to keep

What the law requires. Keep sent and received invoices for seven years from 1 January of the year after issue (art. 60 VAT Code, as amended by the Law of 18 December 2025), longer for some invoices tied to immovable property, with authenticity, integrity and legibility guaranteed: invoice archiving.

What we recommend. Keep the original XML of each structured invoice, the lookup result and customer exchange behind each fallback invoice, written establishment confirmations, any agreement on another format, and a dated screenshot of Peppol → Statut.

What OrdoGrid does. It archives the exact XML and PDF of every Peppol send. Download them from the Outbox row; for received documents, select the rows in Peppol → Inbox and download the ZIP with its xml and pdf folders. OrdoGrid is not a legal archive and guarantees no retention period: file these downloads in your own archive.

FAQ

Is e-invoicing mandatory in Belgium in 2026?

Yes, since 1 January 2026, for supplies between businesses established in Belgium, except art. 44-exempt ones: you issue structured invoices and must be able to receive them. Consumer and cross-border invoices are outside.

Is Peppol itself mandatory?

Peppol BIS over Peppol is the legal default. Another EN 16931 format needs an agreement, preferably written, and you must still be able to use Peppol BIS. A PDF is not such a format.

Does the obligation apply under the small business VAT exemption?

Yes. Franchise taxpayers issue structured invoices to Belgian business customers, without VAT and with the franchise mention, and must be able to receive.

My Belgian customer is not on Peppol. Can I send a PDF?

Yes, under the fallback rule, if it cannot technically receive: a PDF if it accepts electronic invoices, otherwise paper. The invoice issued this way is valid. Keep proof of your check and do not resend that invoice on Peppol later.

Can my customer force me to use its invoicing portal?

No, not without your clear written consent. In principle structured invoices go over Peppol.

Do credit notes have to go through Peppol?

Yes when they correct a structured invoice. A 2026 credit note for a 2025 PDF invoice has no format requirement.

Do I lose my VAT deduction if a supplier sends me a PDF?

Not by itself: under substance over form a complete invoice stays deductible, but the party lacking the means to send or receive risks a fine.

Must I send invoice data to the tax administration?

Not today. The federal coalition agreement plans e-reporting for 2028; a preliminary draft law approved by the Council of Ministers on 18 July 2026 is not yet law, and no official text sets an exact start date yet.