Foreign customers and suppliers: Peppol and the Belgian mandate

Belgium's structured e-invoicing obligation is a domestic rule: since 1 January 2026 it covers invoices between businesses established in Belgium. Foreign businesses, including those with only a Belgian VAT registration, are outside it; the Belgian branch of a foreign company is not. Outside the obligation you may still use Peppol whenever the other party is registered on it.

This guide is for Belgian businesses with foreign customers or suppliers, Belgian branches of foreign groups and their accountants. It answers the channel question: Peppol, PDF or both. Which VAT to charge a customer abroad and which wording the invoice must carry are covered in Invoice business customers abroad. For the full scope of the obligation, see The Belgian e-invoicing obligation.

Is the invoice in scope? Decision tables by counterparty

The obligation in art. 53 §2bis of the VAT Code applies when all three conditions are met:

1. the supplier is a taxable person established in Belgium and invoices under its Belgian VAT number;
2. the customer is a taxable person established in Belgium that must give its Belgian VAT number for the transaction, or a Belgian VAT unit;
3. the supply is not exempt under art. 44 of the VAT Code.

Suppliers under the flat-rate regime (art. 56) and bankrupt suppliers are excluded from issuing; see the Belgian e-invoicing obligation.

FPS Finance (the Federal Public Service Finance, Belgium's tax administration) has applied the establishment test since 1 January 2026, and the Law of 10 February 2026 (Belgian Official Journal, 20 February 2026) wrote it into the Code: a business with no seat and no fixed establishment in Belgium is outside both the issuing and the receiving duty, even if it holds a Belgian VAT number. Invoices to customers in other EU countries and outside the EU are not covered either.

Established in Belgium

Having the seat of the business, or a fixed establishment such as a branch, in Belgium. A Belgian VAT registration on its own does not make a foreign business established here. Whether a given office counts as a fixed establishment is a VAT question to settle with your accountant.

Invoices you send

Invoices you receive

The FPS B2B FAQ has not been updated: on non-established businesses it says the law "is still being amended". That amendment has been in force since 20 February 2026.

The channel does not change the VAT content. Reverse charge, the intra-EU exemption and exports follow the same rules whether you send by Peppol or by email: see Invoice business customers abroad.

A Belgian VAT number does not prove establishment

Since the 2026 change, a customer's BE VAT number tells you less than it used to. A foreign company can hold one without any seat or branch here, for example because it makes taxable supplies in Belgium. FPS Finance says a non-established business must inform its counterparties itself, but you are the one who chooses the channel. Before the first invoice:

1. Ask the customer whether it has its seat or a fixed establishment in Belgium, and which entity places the order.
2. Get the answer in writing: an email or a clause in the order confirmation is enough for your file.
3. Record it in the client's Notes field in OrdoGrid, so whoever invoices next sees it. This is our recommendation, not a legal requirement.
4. If the customer says it is established in Belgium but cannot receive on Peppol, apply the fallback: issue a normal invoice and keep proof, as described in send when the client is not on Peppol.

Peppol across borders: identifiers and reachability

Peppol is an international network. FPS Finance describes its use outside Belgium as voluntary, and says the Peppol Directory shows which customers, "even international clients", are ready to receive.

Each participant is addressed by a scheme code and an identifier. Belgian participants must be registered at least under 0208 with their enterprise number; scheme 9925 (Belgian VAT number) may be added but cannot replace it. Foreign businesses use the schemes of their own country. Examples from the Peppol EAS code list (May 2026 release):

How to check reachability. OrdoGrid checks automatically when you click Envoyer (send; see the steps below). To check by hand, use OpenPeppol's Lookup service with the scheme code and identifier. It shows whether the business can receive, not whether it can send. The Peppol Directory is voluntary and updated with a delay, so a missing Directory entry does not prove that a business is off the network. More tips are in Peppol participant lookup.

A failed lookup means "not found under that identifier". A Dutch company registered only under its KvK number will not be found under its VAT number. Ask the customer which identifier it is registered under. Do not ask Belgian customers for a Peppol ID: FPS Finance says you should not, because the enterprise number is the default.

Neighbouring countries have their own rules

Some foreign customers are now bound by their own country's e-invoicing rules. Those rules govern businesses in that country; they do not change the Belgian obligation, but they explain why a customer may ask you for a structured invoice.

Under the BMF letter, an invoice from a Belgian supplier without a German establishment is not subject to the German obligation. For France, ask the customer how it wants to receive your invoices and take French-law questions to an adviser in France.

Step by step in OrdoGrid

Create the foreign client

1. Open Clients, click Ajouter un client (add a client) and choose Assujetti à la TVA (VAT-registered) as Type de client.
2. Type the N° de TVA with its country prefix, for example NL859301448B01. OrdoGrid looks it up and shows its source: VIES (UE), Registre belge (BCE) or Registre français. Click Pré-remplir (prefill). Numéro de TVA invalide (invalid VAT number) means: check the number with the customer. VIES, the EU's VAT number validation service, covers only EU numbers: for a customer outside the EU, for example with a GB or CH number, the lookup cannot confirm it, so enter the name and address yourself.
3. Check Nom de l'entreprise (company name), the address and Pays (country).
4. In Notes, record the establishment status and how you confirmed it, then click Créer le client.

There is no Peppol ID field on a client: you cannot type a foreign customer's Peppol identifier. OrdoGrid derives it from the VAT number when you send.

Send the invoice

1. In Invoices, click Nouvelle facture (new invoice) and pick the customer with Sélectionner un client. When the customer's VAT number has a different country prefix from yours, the Options de TVA section of the Récapitulatif sidebar shows Client étranger (NL); a foreign company invoiced under a BE VAT number gets no banner. Set the VAT treatment under Options de TVA; Autoliquidation (reverse charge) is offered only when the two VAT numbers have different country prefixes.
2. Click Envoyer. OrdoGrid checks the customer's VAT number on the Peppol network under the identifier schemes it knows for that country, for example 9944 for a Dutch number, then searches the Peppol Directory.
3. Read the Peppol block and act on it:

4. Click Sauvegarder & Envoyer (save and send). When Peppol is skipped, OrdoGrid emails nothing automatically: the Email box must be ticked.
5. Follow the Peppol send in Peppol → Outbox. Traité (processed) means the invoice reached the customer's access point; it does not mean it was accepted or paid. Vérifier (check) refreshes the status now.

Receive invoices from foreign suppliers

• A foreign supplier on Peppol can send to your Belgian identifier: 0208: followed by your enterprise number. You find it in Peppol → Statut, under Annuaire Peppol, as Identifiant Peppol. Reception must be active in OrdoGrid (Réception Peppol → Activer la réception); if another provider holds your registration, the invoices arrive there.
• Received invoices appear in Peppol → Inbox. The detail panel shows Fournisseur (supplier), Numéro (number), Date d'échéance (due date) and Devise (currency), the lines and the totals. See receive supplier invoices.
• OrdoGrid has no purchase ledger. When you owe the VAT on a foreign supplier's invoice (reverse charge), your accountant books it. If you have not yet received that invoice, Royal Decree no. 1 (art. 9) requires you to draw up your own document by the 15th of the month after the month in which the VAT became chargeable.
• An invoice not meant for you: click Répondre (reply) and send RE Rejetée (rejected) with a reason code.
• Peppol does not detect duplicates. If a supplier sends the same invoice by email and by Peppol, book it once.

If your company is not registered for VAT in Belgium

OrdoGrid sends and receives on Peppol only for companies with a BE VAT number. Otherwise the send stops with "Peppol n'est disponible que pour les entreprises enregistrées en Belgique". A Belgian branch with its own BE VAT number can be set up as a separate OrdoGrid company with Créer une nouvelle entreprise, with its own Autorisation Peppol (one is needed per VAT number) and its own reception under 0208.

Worked example: four invoices, four answers

Delvaux Engineering BV in Kortrijk (VAT BE 0745.312.861) maintains industrial machines and sells spare parts. On 30 September 2026 it invoices its September work:

F-2026-0181, step by step. Havenlicht confirmed by email that it has no seat or branch in Belgium, and Delvaux checked its VAT number in VIES on 24 September 2026; both facts are in the client's Notes. The sidebar shows Client étranger (NL); Delvaux chooses Autoliquidation, so the line is at 0% and TVA reads 0.00. When Delvaux clicks Envoyer, OrdoGrid finds Havenlicht under scheme 9944 and ticks Envoi électronique via Peppol; Delvaux unticks Email and clicks Sauvegarder & Envoyer. The Peppol file carries VAT category AE, exemption code VATEX-EU-AE and both VAT numbers, and the Outbox shows Traité once it is delivered.

F-2026-0182. Ateliers Lambert is also on Peppol, under scheme 9957, so OrdoGrid ticks Peppol and Delvaux sends it there. Under Livraison intracommunautaire the file carries the delivery date entered on the invoice, or else the invoice date, and France, from the client's address, as the deliver-to country (see the warning above). Delvaux keeps the signed CMR consignment note and the bank statement showing payment of the carrier as transport proof (see Invoice business customers abroad).

F-2026-0183. The customer is a UK company, but the service goes to its Antwerp branch, which is established in Belgium and gave its BE VAT number. The invoice is in scope. OrdoGrid finds the branch under 0208:1012437597 and sends through Peppol. Had the branch not been found, Delvaux would still issue the invoice under the fallback, by email as a PDF if the branch agreed to that channel or else on paper, and keep a dated record of the failed lookup and of the agreement; the branch, not Delvaux, would be in breach of its duty to receive.

F-2026-0184. OrdoGrid looks Kessler up under 0208:1015880208 and 9925:BE1015880208 and in the Peppol Directory, and shows Le client n'est pas enregistré sur le réseau Peppol. Kessler confirmed in writing that it has no seat or branch in Belgium and accepts PDF invoices, so email is the right channel and no fallback evidence is needed. Delvaux keeps Kessler's confirmation.

What changes in 2028 and 2030

• Belgian e-reporting. Reporting invoice data to the administration is planned for 2028 under the federal coalition agreement. The Council of Ministers approved a preliminary draft law on 18 July 2026; it is not yet law. Today no invoice data is sent to the administration.
• EU rules (ViDA). Council Directive (EU) 2025/516 introduces e-invoicing and digital reporting for intra-EU transactions; Member States must apply these rules from 1 July 2030. FPS Finance states that the obligation will then also apply to invoicing between EU Member States; Belgium has not yet transposed these rules. Details are in e-reporting 2028 and ViDA.

Edge cases

Common mistakes

Evidence to keep

• For each customer with a BE VAT number and a foreign address: its written statement on establishment. For EU customers: your VIES check.
• For each in-scope invoice sent outside Peppol: the date and result of the failed lookup, as proof that the customer could not receive, and, for an emailed PDF, the customer's agreement to that channel.
• Any agreement on another format or channel with a customer in scope; FPS Finance recommends putting it in writing.
• Sent invoices: the PDF and, for Peppol sends, the XML. In Peppol → Outbox, select rows and download the ZIP, which holds an xml/ and a pdf/ folder.
• Received invoices: the bulk ZIP from Peppol → Inbox.

Keep invoices for 7 years from 1 January of the year after issue (art. 60 VAT Code, as amended by the Law of 18 December 2025). OrdoGrid is not a legal archiving service: keep your own copies.

FAQ

Does the Belgian Peppol obligation apply to invoices for foreign customers?

No. It covers invoices between businesses established in Belgium. Invoices to customers in other EU countries or outside the EU may be sent on paper or as a PDF the customer accepts. EU rules for intra-EU e-invoicing apply from 1 July 2030.

My customer is foreign but has a Belgian VAT number. Peppol or PDF?

It depends on establishment. With a seat or fixed establishment in Belgium, the invoice is in scope and goes through Peppol. Without one, it is out of scope since 1 January 2026 and a PDF is valid. If the customer is registered on Peppol, sending there is correct either way.

Is the Belgian branch of a foreign company in scope?

Yes, when the branch is your customer or your supplier. It is established in Belgium, must issue structured invoices and must be able to receive them. A company with a Belgian branch must also give its BE VAT number for supplies that take place in Belgium, even when they are made for its foreign establishment; those invoices are in scope too.

Can I send a Peppol invoice to a customer in another country?

Yes, if the customer is registered on Peppol; FPS Finance treats registration as agreement to receive structured invoices. OrdoGrid finds the customer from its VAT number when you click Envoyer. This includes invoices under Livraison intracommunautaire: OrdoGrid adds the delivery date and deliver-to country that Peppol requires.

Which Peppol identifier does a foreign business use?

A scheme of its own country, for example 9944 for a Dutch VAT number, 9957 for a French one or 9930 for a German one, or a registry number such as KvK or SIRET. The 0208 scheme is only for Belgian enterprise numbers.

Must I accept Peppol invoices from foreign suppliers?

A foreign supplier without a Belgian establishment has no duty to use Peppol. If it does send through Peppol, your registration counts as agreement to receive, and the invoice appears in Peppol → Inbox in OrdoGrid.

Can a company without a Belgian VAT number send Peppol invoices with OrdoGrid?

No. OrdoGrid offers Peppol only to companies with a BE VAT number. A Belgian branch with its own BE VAT number can be set up as a separate company in OrdoGrid.