- Belgium
PDF or structured invoice in Belgium: what is valid from 2026
When a PDF invoice is still valid in Belgian B2B from 2026, how Peppol, Factur-X, portals and PDF copies compare, and how OrdoGrid sends the invoice with its PDF.
- Updated
- Content owner
- Customer education team
- For
- Small business owners and freelancers · Office and finance staff who issue invoices · Accountants advising Belgian SMEs
At a glance
From 1 January 2026, between two VAT-registered businesses established in Belgium (for supplies not exempt under art. 44 VAT Code), the structured e-invoice (Peppol BIS over Peppol by default) is the only legal invoice; a PDF is an optional copy and is not valid on its own. A PDF is still the invoice outside the obligation (consumers, foreign customers) and as the fallback when the customer cannot receive. OrdoGrid's Peppol invoice already carries the PDF inside it.
Before you begin
- Know whether your customer is a business established in Belgium and identified there for VAT
- To send from OrdoGrid: a company with a BE VAT number and a signed Autorisation Peppol (Peppol authorisation)
- Your customer's VAT number, plus any purchase-order number or format agreement it has asked for
What you will achieve
- Pick the legally valid format and channel for each customer
- Send one structured invoice with its PDF and attachments, without duplicates
- Answer customer requests for PDFs, paper or portal uploads correctly
- Keep the right evidence for each route
On this page
From 1 January 2026, an invoice between two VAT-registered businesses established in Belgium must be a structured electronic invoice: data that software can process, sent by default as Peppol BIS over the Peppol network. A PDF can travel with it as a readable copy, but on its own it is no longer the invoice in those cases, however good it looks and however it is delivered.
This guide explains when a PDF is still valid, how the hybrid options compare, what to do when a customer asks for something else, and how OrdoGrid sends the structured invoice with its PDF. Who is covered is explained in the Belgian B2B e-invoicing obligation, and the data inside the file in EN 16931 and UBL.
The rule: which document is the invoice
What the law requires. A business established in Belgium must issue a structured electronic invoice for its supplies to a taxable customer that is also established in Belgium and must give its Belgian VAT number (art. 53 §2bis VAT Code). The default is Peppol BIS in its UBL version, sent over the Peppol network (art. 13ter Royal Decree no. 1). Another format or channel is allowed only by agreement and must still follow the European standard EN 16931 in an approved syntax. Even then, each business must keep the technical means to issue and receive Peppol BIS (art. 13quater).
- Structured electronic invoice
- An invoice issued, transmitted and received in a structured electronic form that allows automatic electronic processing (definition added to the VAT Code by the Law of 6 February 2024). A PDF, even one produced by invoicing software, is a page layout for people, not structured data.
For these transactions, FPS Finance (the federal tax administration) states that the structured invoice is the only legally required invoice. A PDF or paper copy may be sent voluntarily, and the customer cannot reject an invoice because no PDF is attached (B2B FAQ, questions 11 and 12). When the customer cannot technically receive, the supplier must still issue an invoice on paper or as a PDF (art. 53 §2bis, sixth paragraph, Law of 10 February 2026). The general tolerance for businesses that were not ready ended on 31 March 2026.
Decision table: PDF or structured?
| Your situation | What the law requires | What to send |
|---|---|---|
| You and your customer are both businesses established in Belgium, the customer identified there for VAT (even if you use the VAT exemption scheme for small businesses) | Structured invoice, Peppol BIS by default | Peppol; a PDF only as a copy |
| Same, but the customer cannot technically receive structured invoices | Fallback: an ordinary invoice on paper or as a PDF; the customer breaches its own duty to receive | PDF by email (the customer must agree to electronic delivery by a secure method) or paper, and keep proof |
| Same, and you both agreed another EN 16931 format or channel | Allowed; both stay able to use Peppol BIS | The agreed format, under a written agreement |
| Credit note | For a structured invoice: same format as the original. For a 2025 PDF invoice: no format requirement. For a 2026 fallback PDF invoice: the FPS same-format rule targets structured invoices; agree the channel with the customer | Peppol, or a PDF the customer accepts for a 2025 invoice; for a fallback invoice, see client not on Peppol |
| Private individual, or a customer without a Belgian VAT number | Outside the obligation | PDF or paper; email needs the customer's agreement |
| Customer established abroad, even with a BE VAT number (unless it has a Belgian fixed establishment) | Outside the Belgian obligation; intra-EU e-invoicing follows under ViDA from 1 July 2030 | PDF with the customer's agreement, or Peppol if both use it |
| You only make supplies exempt under art. 44 VAT Code, or you are taxed under the flat-rate scheme (art. 56) | No duty to issue structured invoices (flat-rate taxpayers must still be able to receive them) | PDF allowed |
| Belgian public authority (B2G) | Public-procurement rules: e-invoices compulsory, in principle from €3,000 excluding VAT, for contracts published since 1 March 2024 | Peppol (public buyers receive through Mercurius) |
PDF, hybrids and other formats compared
"Hybrid" covers two opposite designs: a PDF that carries XML data (Factur-X, called ZUGFeRD in Germany), and a structured invoice that carries a PDF (Peppol BIS with an embedded PDF). In Belgium only the second is the default.
| Option | Valid as the invoice in an in-scope case? | Conditions and notes |
|---|---|---|
| PDF by email, generated or scanned; paper | No | Valid outside the obligation or as the fallback |
| PDF uploaded to the customer's portal | No | Uploading does not make a PDF structured. A customer cannot impose its portal without your clear written consent (B2B FAQ, question 18) |
| Peppol BIS (UBL) over Peppol, PDF embedded | Yes, the legal default | The UBL data are the invoice; the embedded PDF is a readable copy. This is what OrdoGrid sends |
| Peppol BIS plus the same PDF by email | Yes (the Peppol invoice) | The email is a copy that the customer must not book twice |
| UBL or CII file sent by email or through a portal | Only by agreement | The file must follow EN 16931 in one of the two syntaxes on the EU list: UBL 2.1 or UN/CEFACT CII |
| Factur-X or ZUGFeRD (PDF/A-3 with embedded CII XML) | Only by agreement | The embedded XML must conform to EN 16931 (have your provider confirm the profile); the visible PDF remains a copy |
| EDI message | Only by agreement | Classic EDIFACT is not on the EU syntax list: the message must be an EN 16931 invoice in UBL or CII |
FPS Finance recommends making any agreement on another format or delivery method explicit and written, because an implicit agreement is hard to prove (FAQ on electronic invoicing, question 13). OrdoGrid produces the UBL only for a Peppol send: it creates no Factur-X files, and its emails carry the PDF but no XML.
What we recommend. Send Peppol BIS with the PDF embedded to every Belgian business customer that can receive it. If the PDF and the data ever disagree, the invoice is wrong: no rule lets one override the other. Correct it with a credit note in the same format (on Peppol) and, if needed, a new invoice, never with a different PDF.
What your customer's software does with each format
| Step | Structured invoice | |
|---|---|---|
| Capture | Someone retypes it, or an OCR tool guesses fields from the layout | Labelled fields are imported: parties, lines, VAT per rate, totals, due date, IBAN, payment reference |
| Checks | Errors surface at reconciliation or audit | Rules run before sending: totals must add up exactly (rule BR-CO-15), a Belgian enterprise number must have valid check digits (rule PEPPOL-COMMON-R043) |
| Matching | Text comparison | Buyer reference or order number, invoice number and payment reference |
| Delivery evidence | Your outgoing email; no read receipt | A network delivery status |
Neither channel proves acceptance. A Peppol delivery status confirms network delivery, not that the customer read or approved the invoice; the Message Level Status that providers are phasing in during 2026 and 2027 is also a report between providers. Only an Invoice Response, optional in standard Peppol, gives the customer's decision, such as AP (accepted) or RE (rejected).
Attachments travel with the invoice
What the law requires. Documents that support an invoice, such as a timesheet, delivery note or signed order, legally form part of it. They must travel through the same channel: embedded in the UBL invoice, or through a link in it when a file is too large. Sending them separately by email conflicts with the law (B2B FAQ, questions 19 to 22). Peppol accepts embedded PDF, PNG, JPEG, CSV, XLSX and ODS files (Peppol BIS Billing 3.0, section 7.2.10). FPS Finance adds that XML may already be used if both parties agree (B2B FAQ, question 19), but XML is not yet on the Peppol code list: an embedded XML file currently fails Peppol validation.
What OrdoGrid does. Files added under Documents et Références in the invoice editor are included in the Peppol invoice by default (2 MB in total for all attachments of one invoice). The editor also accepts DOC, DOCX, XLS and GIF, but Peppol does not (rule PEPPOL-EN16931-CL001) and the send fails: convert them to PDF first. When you send from the invoice list with Envoyer à Peppol (send to Peppol), the confirmation window offers Fichiers additionnels (optionnel) (additional files) for PDF, CSV, PNG, JPEG, XLSX or ODS files up to 5 MB each, and adds the invoice PDF as the main document automatically.
When the customer asks for something else
| Customer request | What the law says | What to do |
|---|---|---|
| "Please also email us the PDF" | A PDF copy is voluntary; the Peppol invoice stays the invoice | Send on Peppol; email a copy only if asked, marked as a copy. Peppol cannot detect duplicates (specific FAQ, question 4), and the Belgian Peppol providers' forum recommended on 8 September 2026 sending only via Peppol when the recipient receives there |
| "Send the PDF (or paper) only, our accounts payable is not ready", although the customer is on Peppol | A PDF or paper invoice alone is not valid; the customer must be able to receive | Send on Peppol; add a copy if it helps them |
| "Upload your invoices to our portal" | Not without your clear written consent | Reply that you invoice via Peppol. If you accept the portal, confirm it in writing, make sure what you submit there is an EN 16931 invoice in UBL or CII (an uploaded PDF is still not the legal invoice) and stay able to send and receive on Peppol |
| "We are not on Peppol yet", and a lookup confirms it | Fallback: you issue a PDF or paper invoice; the customer stays liable for not receiving | Email the PDF once the customer agrees to electronic delivery by a secure method, keep proof and never resend that invoice on Peppol later (B2B FAQ, question 8) |
How OrdoGrid sends the structured invoice and its PDF
Your company needs a BE VAT number and a signed Autorisation Peppol; the complete first send is in send your first Peppol invoice. Many labels stay French in every interface language.
- Save the invoice, then click Envoyer (send) in the editor header. The window Envoyer la facture opens.
- Wait until Vérification de l'éligibilité... (checking eligibility) disappears. When OrdoGrid finds the client on Peppol from its VAT number, Envoi électronique via Peppol (electronic sending via Peppol) is ticked.
- Decide on Email. It is pre-ticked whenever the client has an email address; if you leave it ticked, the PDF is also emailed at the same time as the Peppol send, a second copy of the same invoice. Untick it unless the client asked for a copy.
- Check the attachments under Documents et Références: they travel inside the Peppol invoice.
- Click Sauvegarder & Envoyer (Save & Send) once. A result appears for Sauvegarde (save), Email and Peppol.
- Open Peppol → Outbox. Traité means network delivery, not acceptance or payment.
| Channel | What your client receives | Legal role in an in-scope case |
|---|---|---|
| Peppol | Peppol BIS Billing 3.0 UBL invoice with the PDF embedded, plus your attachments | The invoice |
| Email, from the send window or the list action Send by email | An email with the PDF; never the XML | A copy (the invoice itself for out-of-scope customers and in the fallback) |
If the Peppol block shows Peppol — ignoré (skipped), OrdoGrid does not switch to email by itself, but Email stays ticked when the client has an address: untick it unless email is the right channel. With Pas de numéro de TVA client (no client VAT number), email is right for a private customer; for a business, add its VAT number. With Le client n'est pas enregistré sur le réseau Peppol (client not registered on Peppol), check the number with the client, then follow client not on Peppol. With Impossible de vérifier le statut Peppol du client (could not check the client's Peppol status), close the window and try again later; this is not evidence that the client cannot receive.
To send on Peppol later, for example after emailing a PDF by mistake, use the globe button Envoyer à Peppol in the Factures list; its window shows a PDF preview and Client inscrit sur Peppol (client registered on Peppol). Once an invoice is sent on Peppol, its amounts are locked: corrections go through a credit note, also sent on Peppol.
Worked example: one invoice, three routes
Atelier Nord SRL, a joinery workshop in Namur, has fitted an oak bar counter for Brasserie Delvaux SRL in Brussels. Both are VAT-registered and established in Belgium, and Brasserie Delvaux receives on Peppol. Its purchase-order number, BC-7781, is entered in N° bon de commande (purchase-order number).
| Field | Value |
|---|---|
| Invoice | F-2026-0042, dated 12 October 2026, due 11 November 2026 |
| Line 1 | Oak counter, made to measure: 1 × €1,850.00 = €1,850.00, VAT 21% |
| Line 2 | Fitting on site: 8 h × €75.00 = €600.00, VAT 21% |
| Total excluding VAT | €2,450.00 |
| VAT 21% | €514.50 |
| Total including VAT and amount due | €2,964.50 |
| Structured communication | +++002/0260/04240+++ |
Route 1: PDF only (wrong here). On 12 October the office manager emails the PDF. Brasserie Delvaux's accountant replies that the company receives on Peppol and asks for the structured invoice. Had a bookkeeper retyped the PDF with €541.50 VAT instead of €514.50, the deductible VAT and the amount paid would both be €27.00 too high, unnoticed until reconciliation. The fix: send the same invoice, F-2026-0042, with Envoyer à Peppol in the Factures list and ask the customer to book only the Peppol invoice and treat the emailed PDF as a copy; never a second number for the same sale.
Route 2: Peppol with the PDF inside (correct). The office manager opens F-2026-0042, clicks Envoyer, leaves Envoi électronique via Peppol ticked, unticks Email and clicks Sauvegarder & Envoyer. A few minutes later the Outbox shows Traité. Brasserie Delvaux's software reads:
| Data | EN 16931 term | Value read |
|---|---|---|
| Invoice number, issue date, due date | BT-1, BT-2, BT-9 | F-2026-0042, 2026-10-12, 2026-11-11 |
| Buyer reference (OrdoGrid puts the purchase order here) | BT-10 | BC-7781 |
| Total excluding VAT | BT-109 | 2450.00 |
| Total VAT | BT-110 | 514.50 |
| Total including VAT and amount due | BT-112, BT-115 | 2964.50 |
| Payment reference | BT-83 | The structured communication |
| Attached document | BT-125 | F-2026-0042.pdf |
OrdoGrid validates the file before delivery, so 2,450.00 + 514.50 must equal 2,964.50 exactly (rule BR-CO-15). Nothing is retyped on the customer's side.
Route 3: fallback for a customer that cannot receive. The same week, Atelier Nord invoices Garage Lambert SRL in Liège €400.00 + €84.00 VAT = €484.00 (F-2026-0043). The send window shows Peppol — ignoré with Le client n'est pas enregistré sur le réseau Peppol. Atelier Nord confirms the VAT number, finds nothing for 0208: followed by the enterprise number on lookup.peppol.org, saves a dated screenshot, obtains Garage Lambert's written agreement to receive PDFs and sends by Email only. The PDF is a valid invoice, and Garage Lambert is the one exposed to fines for not receiving. When it joins Peppol in December, F-2026-0043 is not resent; only new invoices go on Peppol.
Edge cases and common mistakes
| Situation | Correct action |
|---|---|
| The customer booked both the Peppol invoice and an emailed copy | You issued one invoice: ask the customer to reverse the duplicate entry. Detecting duplicates is the recipient's job (specific FAQ, question 4) |
| An invoice sent on Peppol is wrong | Issue a credit note that refers to it, on Peppol (same format: specific FAQ, question 5), then a new invoice if needed |
| A Belgian supplier sends you only a PDF | You may in principle refuse it and ask for the structured invoice (B2B FAQ, question 7); you must be able to receive yourself |
| PDF that is the invoice (fallback, or a business customer outside the obligation), entered with VAT-inclusive prices | Untick Prix unitaires TVAC (TVA incluse) before issuing, so the PDF shows the unit prices excluding VAT that a full invoice requires, then check that the totals have not changed |
Evidence to keep
What the law requires. Keep 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), with authenticity, integrity and legibility guaranteed throughout. Some invoices linked to business real estate may have to be kept 15 or 25 years. The recipient keeps the structured invoice itself; a PDF or viewer may provide legibility but must not change the content (B2B FAQ, question 17). Keeping the original XML is not mandatory, but FPS Finance strongly recommends it (archiving guidance). More: invoice archiving in Belgium.
What OrdoGrid does. For each Peppol send it archives the exact XML and PDF transmitted, with their hashes. Download them from the Outbox row (XML or PDF), or select rows to get a ZIP with an xml/ and a pdf/ folder. OrdoGrid is not a legal archive and guarantees no retention period.
What we recommend.
| Route | Keep |
|---|---|
| Peppol | The XML and PDF, the Traité date and any Invoice Response |
| Fallback PDF | The PDF as sent, the dated lookup result and the customer's agreement to receive PDFs by email |
| Agreed alternative format or portal | The written agreement and the files as sent, with any portal receipt |
| Out-of-scope PDF | The PDF as sent and, for email, the customer's agreement to electronic invoices |
FAQ
Is a PDF invoice still valid in Belgium in 2026?
Between two VAT-registered businesses established in Belgium, for supplies not exempt under art. 44 VAT Code, not on its own: the structured e-invoice is the only legal invoice and a PDF is an optional copy. A PDF remains the invoice for consumers, for customers outside the obligation and in the fallback.
Is Factur-X or ZUGFeRD accepted in Belgium?
Only as an alternative agreed with the customer, preferably in writing. Its embedded XML must follow EN 16931, and both parties must still be able to send and receive Peppol BIS. OrdoGrid does not produce Factur-X.
My customer wants the PDF by email as well. Is that allowed?
Yes, as a copy. Send the invoice on Peppol and mark the email as a copy so it is not booked twice. Belgian Peppol providers recommend sending only via Peppol when the customer can receive there.
Where do timesheets and delivery notes go?
Inside the Peppol invoice, as PDF, PNG, JPEG, CSV, XLSX or ODS attachments. FPS Finance treats supporting attachments as part of the invoice, so sending them separately by email conflicts with the law.
Our customer's accounts payable still wants paper. What do I do?
If the customer can receive on Peppol, send the structured invoice and post a paper copy marked as a copy if you wish. If it truly cannot receive, a paper or PDF invoice is the legal fallback and the customer carries the risk of fines.
Can my customer deduct VAT on a PDF invoice?
In principle, deduction relies on the structured invoice. FPS Finance applies substance over form: a PDF or paper invoice with all legal mentions does not lose deduction for that reason alone, but fines for the format remain possible (specific FAQ, question 24).
Which file should I archive, the PDF or the XML?
Keep the invoice for at least seven years. The original format is not mandatory, but FPS Finance strongly recommends keeping the XML; keep the PDF next to it as the readable copy.
Sources and references
- FPS Finance — FAQ: general questions on the B2B obligation (questions 7 to 22)
- FPS Finance — FAQ: specific questions about e-invoicing (questions 4, 5, 23 and 24)
- FPS Finance — FAQ: general questions on electronic invoicing (question 13, alternative formats)
- Royal Decree no. 1 on VAT (consolidated, Justel), arts. 13ter and 13quater
- Law of 10 February 2026 on various VAT provisions (Belgian Official Journal 20.02.2026), fallback rule
- European Commission — Required syntaxes for EN 16931 (UBL 2.1 and UN/CEFACT CII)