Belgian e-invoicing checklist 2026: audit sending, receiving, records

Since 1 January 2026, a business established in Belgium that falls under the e-invoicing obligation must send structured invoices to its Belgian business customers and be able to receive them, by default in Peppol BIS over the Peppol network. The tolerance periods are over, so this checklist is no longer about getting ready: it audits whether sending, receiving and record-keeping actually work, and whether you could show it to FPS Finance (the federal tax administration).

It is written for OrdoGrid users, from sole traders to finance teams. It does not decide whether you are in scope (the Belgian e-invoicing obligation), what a gap costs (penalties) or how to archive in detail (invoice archiving). Every row ends in one of two states: done, with dated evidence, or open, with an owner and a date.

Which checklist to run

Businesses under the small business VAT exemption (franchise) are not art. 44 businesses: they must send structured invoices to Belgian business customers and must receive, so every row applies.

Part A: the 15-minute quick check

Rows 1 to 5, 7 and 8 test legal requirements; the dated proof in row 8 is our recommendation. Rows 6 and 9 are the routine we recommend to keep them met.

Traité means delivered on the Peppol network, not accepted or paid by the customer.

Example: a freelance translator's quarter

On Thursday 1 October 2026, Sofie Peeters, a freelance translator in Leuven under the normal VAT regime, runs part A. Statut shows Envoi + réception, Autorisé and Enregistré. Her September invoice F-2026-0018 to Vertaalbureau Lingua BV (12,500 words × €0.12 = €1,500.00 + 21% VAT €315.00 = €1,815.00) shows Traité. The Inbox holds one unread invoice from her coworking space: she checks it, marks it read and downloads the quarter's ZIPs for her accountant. After about 15 minutes nothing is open.

Part B: the full audit

Run part A first. Part B adds what a team, a second provider or an integration tends to break. In the Basis column, "Law" marks a legal requirement, "Recommended" our advice, "OrdoGrid" a product requirement, and an FPS Finance FAQ or Belgian Peppol rule the administration's guidance.

Identity and reachability

OrdoGrid registers only 0208:, not your VAT number under scheme 9925: if a supplier's software searches by VAT number and finds nothing, ask it to search 0208:. VAT units are not covered here; confirm with your accountant which VAT number you invoice under, and the Peppol registration with OrdoGrid support.

Sending

OrdoGrid also accepts GIF, Word and XLS attachments, which the European standard does not allow. Attachments go into Peppol sends by default, and OrdoGrid's validation then refuses the send: attach only the five formats above, or convert the file to PDF. Belgian Peppol providers advise against also emailing a PDF to customers that receive on Peppol (a recommendation of the Belgian Peppol Service Providers Forum of 8 September 2026, not a ban). Once an invoice has gone on Peppol its amounts are locked: correct it with a credit note (correct or credit an invoice).

Fallback invoices: keep a log

Fallback invoice

An ordinary PDF or paper invoice to a Belgian business customer that cannot technically receive structured invoices (art. 53 §2bis, sixth paragraph, VAT Code, applied since 1 January 2026). It is legally valid; the customer stays in breach of its own duty to receive.

OrdoGrid never falls back to email by itself. When the send popover shows Peppol — ignoré (Peppol skipped) with Le client n'est pas enregistré sur le réseau Peppol (the customer is not registered on the Peppol network):

1. Look the customer up on lookup.peppol.org with 0208: and its enterprise number; check the VAT number in your client file.
2. Ask the customer which provider receives for it. Impossible de vérifier le statut Peppol du client is a failed check, not proof: retry later.
3. If it really cannot receive, send the PDF by Email if it accepts electronic invoices, otherwise on paper.
4. Log the date, invoice number, lookup result and the customer's reply.
5. Once it can receive, send new invoices on Peppol. Never resend old ones.

Receiving

OrdoGrid cannot issue self-billed invoices, but its reception registration covers Peppol invoices, credit notes, Invoice Responses and the self-billing document types. Before a customer starts self-billing you, agree a first document and check it reaches your Inbox. Full routine: receive supplier invoices.

Who owns what

An accountant who should only look can be invited in Team with the Viewer role, which is read-only.

Records and evidence

What the law requires. Keep sent and received invoices for seven years from 1 January of the year after the invoice date (art. 60 VAT Code as amended by the Law of 18 December 2025, for VAT chargeable from 1 January 2023; the ten-year period introduced in 2022 was reversed), longer for some invoices linked to immovable property, with authenticity, integrity, legibility and a backup. FPS Finance approves no archiving system.

What we recommend. Keep the original XML as well as the PDF, as FPS Finance strongly recommends, and open one old file each quarter to prove it is still legible.

What OrdoGrid does. It archives the exact XML and PDF of each Peppol transmission and never rewrites them, but it is not a legal archive and guarantees no retention period. Download from an Outbox or Inbox row (XML or PDF), as a ZIP with xml and pdf folders after selecting rows on the Peppol page (sent and received documents come as separate ZIPs), or by API with GET /api/v1/peppol/documents/{id}/xml and the peppol:read scope.

When to run it again

New company in 2026: first steps

1. VAT number first. OrdoGrid sends on Peppol only for companies with a BE VAT number. Enterprise numbers issued since 19 September 2023 start with 1: check that your customers' software accepts it.
2. Create the company. In the profile menu, click Créer une nouvelle entreprise, enter the VAT number and check the data taken from the Belgian register.
3. Authorise sending with the Autorisation Peppol: a typed name and a checkbox, not a qualified electronic signature.
4. Activate receiving on Réception Peppol, which normally shows Pas encore trouvé sur le réseau Peppol (not yet found on the Peppol network). If it shows Déjà inscrit sur le réseau Peppol, someone registered you elsewhere, for example through an accountant's tool: find out which provider first.
5. Look yourself up on lookup.peppol.org.
6. Send your first invoice to a Belgian business on Peppol and check that it shows Traité.

Starting under the small business VAT exemption (franchise)? You are in scope both ways, and the €25,000 threshold (€26,000 from 1 January 2027) is reduced pro rata for a start during the year. The legal mention since 2025 is "Régime particulier de la franchise de taxe" ("Bijzondere vrijstellingsregeling van belasting" in Dutch); OrdoGrid prints it on French and Dutch documents when you choose Régime de la franchise de taxe; English and German documents carry a translation, as no official wording exists in those languages: franchise invoicing.

Worked example: Imprimerie Delvaux's third-quarter audit

Imprimerie Delvaux SRL, a print shop in Namur (enterprise number 0458.213.944, normal VAT regime), invoices from OrdoGrid. The manager is the Owner, the office manager an Administrator, the accountant a Viewer. On Tuesday 6 October 2026 the office manager runs parts A and B for 1 July to 30 September.

Check: €3,700.00 − €740.00 = €2,960.00 net, and €2,960.00 × 1.21 = €3,581.60. The 12 Hautot PDFs stay valid and, being complete, deductible; they are not resent. Until 6 October, however, Delvaux was exposed to the fine for lacking the means to receive. Four rows are closed the same day; the two open ones each have an owner and a date.

Common mistakes

Evidence pack to file after each run

• The evidence from part A: the dated Statut screenshot (with Annuaire Peppol and Autorisations (n)), the lookup result and the quarter's ZIPs.
• The completed checklist, with an owner and a date for each open row, and the fallback log.
• Written agreements and confirmations: formats other than Peppol BIS, self-billing, customers' establishment, and the other provider's confirmation if it receives for you.
• Invoices for your e-invoicing subscription: small companies and self-employed persons can deduct 120% of these costs for taxable periods 2024 to 2027; ask your accountant.

FAQ

Is there still a tolerance period for Belgian e-invoicing?

No. The general tolerance covered 1 January to 31 March 2026 and the self-billing tolerance ended on 30 June 2026. FPS Finance now waives a fine only in exceptional cases, after an individual analysis.

How often should I run this checklist?

Part A every quarter, the full audit after any change of VAT number, Peppol provider, entity or invoicing tool. This is our recommendation: the law sets no audit frequency.

Do I need to send test or pilot invoices?

No. A real invoice showing Traité proves sending, a successful lookup shows your receiving registration, and the first supplier document in your Inbox confirms reception. OrdoGrid has no Peppol test mode, so a test invoice would reach the customer as a real one.

Should I give my suppliers a Peppol ID?

No. In Belgium you are registered under your enterprise number with scheme 0208, and suppliers deliver to it by default. FPS Finance says customers should not be asked for a Peppol ID.

Is a PDF archive enough?

The law allows another format if authenticity, integrity and legibility are guaranteed for seven years, but FPS Finance strongly recommends keeping the XML. OrdoGrid keeps the exchanged XML and PDF and lets you download both, but it is not a legal archive and guarantees no retention period: keep your own copies.

A Belgian customer is not on Peppol. Does that fail my checklist?

No, if you issued a fallback invoice and logged the proof: the customer is the one in breach. Once it can receive, send its new invoices on Peppol.

Does OrdoGrid tell me whether I am in scope?

No. It shows whether you can send and receive and, when you send, whether a customer can receive on Peppol, but scope depends on VAT status and establishment: see the obligation article or ask your accountant.