Belgian e-invoicing penalties: €1,500–€5,000 fines and enforcement

Since 1 January 2026, a business established in Belgium that falls under the structured e-invoicing obligation must have the technical means to issue and receive structured e-invoices. If it does not, FPS Finance (the federal tax administration) can impose a fixed fine: €1,500 for a first infringement, €3,000 for a second and €5,000 for each further one. The ordinary fines for missing, late or incorrect invoices still apply alongside.

This reference is for business owners, accountants and finance teams who want to know their exposure and close it. Who is in scope is explained in the Belgian e-invoicing obligation; what to do when a customer cannot receive is in sending to a customer not on Peppol.

The fines the law sets

The French text of the new infringement reads "Non-disposition des moyens techniques permettant d'émettre et de recevoir une facture électronique structurée". The provision sanctions a situation, not an invoice: the amount is the same whether your invoices total €200 or €200,000. FPS Finance lists these fines in question 26 of its FAQ and confirms that its 2018 fine policy still applies.

Technical means to issue and receive

Being able, yourself or through a service provider, to send and receive invoices and credit notes in Peppol BIS, the UBL format used on the Peppol network. In Belgium this means being registered on Peppol at least under scheme 0208 with your 10-digit enterprise number from the KBO/BCE (Crossroads Bank for Enterprises) and having published that you can receive Peppol BIS Billing invoices and credit notes. Art. 13quater of Royal Decree no. 1 requires these means even if you agreed another format with a customer.

How second and further fines are counted

An infringement counts as a second or further one only if the administration establishes it at least three months after the previous infringement that led to a fine.

The decree does not fine each invoice: the infringement is the lack of means. It does not say how many infringements one audit can record, so do not assume either that one fine covers every past invoice or that each invoice is fined.

Who can be fined: supplier, customer or both

The FPS Finance FAQ (questions 7, 8 and 24) answers the common situations. "In scope" means a supply between two businesses established in Belgium, where the customer must give its Belgian VAT number.

The fallback rule is art. 53 §2bis, paragraph 6 of the VAT Code, added by the Law of 10 February 2026 and applied by FPS Finance since 1 January 2026. It protects the supplier, not the recipient: a customer that cannot receive stays in breach of its own duty.

Which half of the obligation applies to you

Tolerance and enforcement: status on 13 October 2026

As of 13 October 2026, the 7 April 2026 notice is still the latest e-invoicing news from FPS Finance.

Check and close your gaps in OrdoGrid

OrdoGrid connects to Peppol through a certified access point. It sends on Peppol only for companies with a Belgian VAT number, and receiving is a separate opt-in. It sends nothing to FPS Finance and cannot tell you whether you are in scope.

1. Open the status. Go to Peppol → Statut (Status). Under Statut d'inscription Peppol, the badge reads Envoi + réception (send and receive) or Envoi seul (send only); the document tabs show the same as Mode : Envoi + réception or Mode : Envoi seul.
2. Sending. Envoi (Outbox) must show Autorisé (Authorised) with your VAT number. If not, open Autorisation Peppol, type the Nom complet du signataire (signatory's full name), tick the confirmation box and click Signer et confirmer l'autorisation (Sign and confirm the authorisation).
3. Receiving. Réception (Inbox) should show Enregistré (Registered) with a "Depuis le" (since) date. If it shows Non enregistré (Not registered) and no other provider receives for you, click Activer la réception (Activate reception): OrdoGrid registers 0208: plus your enterprise number for Peppol BIS invoices and credit notes, among other document types.
4. Receiving elsewhere. If Réception Peppol shows Déjà inscrit sur le réseau Peppol (Already registered on the Peppol network), another provider holds your registration. Choose Continuer en envoi seul (Continue with sending only) and make sure that provider's inbox is actually monitored.
5. Identity. Under Annuaire Peppol (Peppol directory), note your Identifiant Peppol (Peppol identifier) and Documents supportés (supported documents). Check from outside at lookup.peppol.org by entering 0208: and your enterprise number; it shows receiving capability, not sending.
6. Send in-scope invoices on Peppol. In the editor, click Envoyer (Send), keep Envoi électronique via Peppol (Electronic sending via Peppol) ticked and click Sauvegarder & Envoyer (Save & Send). In Peppol → Outbox, Traité (Processed) means delivered on the network, not accepted; act on Erreur (Error). If the popover says Le client n'est pas enregistré sur le réseau Peppol (The customer is not registered on the Peppol network), confirm on lookup.peppol.org and keep the dated result as proof that the customer could not receive, then send by Email if the customer agrees to receive PDF invoices (otherwise on paper).
7. Watch the inbox. Inbox shows an unread badge, and owners and admins get an email for new documents. Actualiser (Refresh) fetches them immediately.

Step-by-step set-up is in set up Peppol in OrdoGrid, and handling received invoices in receive supplier invoices.

Worked example: a receiving gap found in a VAT audit

Menuiserie Lambert SRL in Liège has invoiced Belgian contractors from OrdoGrid over Peppol since January 2026. During set-up it clicked Continuer en envoi seul, and no other provider receives for it. Its suppliers therefore send PDFs under the fallback rule, for example:

That PDF is a valid invoice, and Lambert keeps its €504.00 deduction because the invoice has all legal mentions. Lambert itself, however, is exposed to the capability fine.

The table below compares three scenarios. Scenario A: Lambert fixes the gap the day after the finding. Scenario B: the gap stays open and only the findings shown are fined. Scenario C: a new finding within three months of the first.

If Lambert never fixes the gap, three findings at the earliest counting dates cost €1,500 + €3,000 + €5,000 = €9,500, and each further finding adds €5,000, whatever the value of the invoices involved.

In scenario A, from 13 May 2026 Bois Dethier can no longer rely on the fallback and must send Lambert structured invoices. Its earlier PDF invoices stay valid, and FPS Finance asks suppliers not to resend them on Peppol.

Common mistakes

Evidence to keep

• A dated screenshot of Peppol → Statut (Envoi (Outbox): Autorisé, Réception (Inbox): Enregistré with its "Depuis le" date, and Autorisations (n)), plus a dated lookup.peppol.org result for your 0208: identifier.
• If another provider receives for you: your contract or its written confirmation.
• The XML and PDF of every invoice and credit note sent and received. On the Peppol page, select rows and download a ZIP with xml and pdf folders; integrations can use GET /api/v1/peppol/documents/{id}/xml. Keep them 7 years from 1 January of the year after issue; see invoice archiving.
• For each fallback invoice: dated proof that the customer could not receive, and the PDF you sent.
• Written agreements for any format other than Peppol BIS.
• Any fine notice, your request or appeal, and the decision.

OrdoGrid archives the exact XML and PDF of each Peppol transmission and does not rewrite them, but it offers no legal-archiving service or retention guarantee. Keep your own copies.

If you receive a fine notice

FPS Finance's fine policy, Instruction 2018/I/41 (nos. 39 to 56), sets out the procedure:

1. Read the notice. It must state the routes of appeal and the competent service; if it does not, the appeal period does not start.
2. Close the gap first and keep dated proof: the policy's remission rules look at whether you meet the sanctioned obligation when you file.
3. Choose a route. File an optional administrative appeal, or a request for remission or reduction under art. 9 of the Regent's Decree of 18 March 1831 to the service named in the notice (usually the centre director). You can also go straight to the tax court (the court of first instance): VAT has no compulsory administrative stage.
4. Mind the timing. No legal deadline applies to a remission request, but FPS Finance asks you to file within three months and suspends collection during that period.
5. Do not count on automatic remission. The policy remits the fine for certain first infringements committed in good faith, but its 1 January 2025 update predates the new fine and does not mention it. A remitted fine still counts as a fined infringement for later ones (no. 56).

Recommended routine

These are our recommendations, not legal obligations.

1. Check each new Belgian business customer on lookup.peppol.org before the first invoice, and keep the result.
2. Look at the Peppol Inbox at least weekly and pass received invoices to whoever books them.
3. Re-check Statut every quarter and after any change of provider or VAT number.

Separately, small companies and self-employed persons can deduct 120% of e-invoicing software subscription costs for taxable periods 2024 to 2027; ask your accountant.

Run the full go-live audit with the 2026 e-invoicing checklist.

FAQ

How much is the fine for not being on Peppol in Belgium?

€1,500 for a first infringement, €3,000 for a second and €5,000 for each further one, under Royal Decree no. 44 as amended by the Royal Decree of 8 July 2025. The amounts are fixed and do not depend on the value of your invoices.

Does the tolerance period still apply?

No. The general tolerance covered 1 January to 31 March 2026, and the self-billing tolerance ended on 30 June 2026. Outside these tolerances, FPS Finance decides not to impose a fine only in exceptional circumstances, after an individual analysis.

Can my customer be fined if I send a PDF invoice?

If you send a PDF because you cannot issue structured invoices, you are the one at risk; your customer may refuse the invoice, or accept it and keep its deduction. If you send a PDF because your customer cannot receive, the customer is at risk and your invoice is valid.

Is sending enough if I cannot receive?

No. Unless you are exempt from receiving, activate reception in OrdoGrid or make sure another provider receives for you.

Is every non-structured invoice a separate fine?

The capability fine sanctions the lack of means, not each invoice, and the decree does not say how many infringements one audit can record. A missing or inaccurate structured invoice can separately bring a proportional fine.

Do I get three months to fix the problem after a fine?

No. The three months only decide when a new finding counts as a second or further infringement. A new infringement can still be established within those three months.

Do the ordinary VAT invoicing fines still apply?

Yes. The fines in Royal Decrees no. 41 and no. 44 for missing, incorrect or late invoices apply to structured invoices too.

How can I contest an e-invoicing fine?

The notice must state your routes of appeal: an optional administrative appeal, a request for remission or reduction under art. 9 of the Regent's Decree of 18 March 1831, or an action before the tax court. FPS Finance asks you to file a request within three months; involve your accountant.