Peppol or EDI invoicing in Belgium: what is compliant from 2026

Since 1 January 2026, an invoice between two businesses established in Belgium must be a structured electronic invoice that follows the European standard EN 16931. The legal default is Peppol BIS (UBL) sent over the Peppol network. An existing EDI link can carry these invoices instead only if both parties agree and the message is an EN 16931 invoice in UBL 2.1 or UN/CEFACT CII; a classic EDIFACT invoice message does not qualify. Whatever you agree, your business must still be able to send and receive Peppol BIS.

This guide is for suppliers whose large customers run EDI, VAN or portal flows, and for the finance and IT teams that maintain them. It helps you classify each flow, pick the legal channel per customer and run EDI and Peppol together without duplicate invoices. Who falls under the obligation is explained in the Belgian B2B e-invoicing obligation; the fields inside a structured invoice in EN 16931 and UBL.

The rule: what an EDI link may carry from 2026

What the law requires. A taxable person established in Belgium must issue a structured electronic invoice for supplies to a taxable customer that is established in Belgium and must give the supplier its Belgian VAT number (art. 53 §2bis VAT Code). Royal Decree no. 1 sets the format and the channel:

FPS Finance (the federal tax administration) recommends making any agreement on another format or channel explicit and written, because an implicit agreement can only be inferred from conduct and is hard to prove (FAQ on electronic invoicing, question 13). Neither side can impose its preference: a customer cannot require you to use its portal without your clear written consent (B2B FAQ, question 18), and a customer registered on Peppol has thereby agreed to receive structured invoices there (question 9).

EU syntax list

The list, adopted under Directive 2014/55/EU, of the two syntaxes in which an EN 16931 invoice may be expressed: UBL 2.1 invoice and credit note messages, and the UN/CEFACT Cross Industry Invoice (CII) D16B. The European Commission states that UN/EDIFACT is not on the list.

The standard does have a technical binding for EDIFACT (CEN/TS 16931-3-4, INVOIC D16B). Because EDIFACT is not on the syntax list, Belgian law does not accept it, even when it is fully mapped to EN 16931 (European Commission, required syntaxes).

Classic EDI

Electronic data interchange set up per trading relationship: a message format (often EDIFACT, such as the EANCOM subset used in retail, or the buyer's own XML) sent over a channel built for that partner, such as a VAN (value-added network), AS2, SFTP or a supplier portal.

Which flows are valid for an in-scope Belgian B2B invoice

Outside the Belgian obligation (customers established abroad, private individuals), an EDIFACT invoice remains an ordinary electronic invoice that needs the customer's agreement. Messages that are not invoices, such as orders (ORDERS) and despatch advices (DESADV), are not covered by the obligation and can stay on EDI.

Peppol and classic EDI compared

Peppol is itself a form of EDI: structured data exchanged between systems. The difference is that the network, the identifiers and the rulebook are shared, so one connection reaches every registered business. For the network basics, see Peppol access points.

What ‘certified’ means for a Peppol access point

In Belgium a Peppol service provider joins OpenPeppol, signs the Peppol service provider agreement with the Belgian Peppol Authority, passes conformance tests with test certificates, receives production certificates and is then added to OpenPeppol's and the Authority's lists of certified providers (Belgian Peppol Authority). FPS BOSA has held that role since 2016; FPS Finance takes it over from 2027. To check a provider, including an EDI provider that also offers Peppol, look for it on OpenPeppol's list of certified service providers, which shows each provider's Peppol Authority. OpenPeppol also requires its service providers to hold ISO/IEC 27001 or an approved equivalent by 1 October 2027; that obligation is on the provider, not on you.

Costs to compare

Ask for quotes line by line, because prices vary by provider and volume. Small companies and self-employed natural persons can deduct 120% of their invoicing-software costs for issuing, sending and receiving structured invoices, such as subscriptions and implementation advice but not depreciation, for taxable periods 2024 to 2027 (Law of 6 February 2024); ask your accountant whether a given EDI or VAN fee qualifies.

Test an existing EDI invoice flow in six questions

Run this check for each customer that receives your invoices outside Peppol.

1. Which syntax is the invoice message? EDIFACT, a proprietary XML or a flat file: not compliant for an in-scope customer, so go to the channel decision below. UBL 2.1 or CII D16B: continue.
2. Does it declare and pass EN 16931? The specification identifier (BT-24) should start with urn:cen.eu:en16931:2017, and your provider should show a clean validation report against the official EN 16931 rules for real invoices and credit notes.
3. Is there a written agreement naming the format, the channel, the document types (invoices and credit notes) and the start date?
4. Can both parties still issue and receive Peppol BIS? Look up your own registration and the customer's on lookup.peppol.org by entering 0208: followed by the enterprise number. The lookup shows the ability to receive, not to send: for sending, ask the customer (or your own provider) to confirm in writing.
5. Do attachments travel inside the message? Supporting documents legally form part of the invoice and must use the same channel, not a separate email (B2B FAQ, questions 19 to 22).
6. Is it the only channel for those invoices? We recommend one channel: a second copy as a Peppol invoice, PDF or portal upload is not forbidden (a PDF copy is optional), but Peppol cannot detect duplicates and the Belgian Peppol service providers' forum advises against dual sending.

A flow that passes all six questions can stay. Questions 1, 2, 4 and 5 are legal conditions: any ‘no’ means moving that customer to Peppol or fixing the flow before the next invoice. Questions 3 and 6 are our recommendations: an agreement can legally be implicit, but a written one makes the flow provable, and a single channel prevents double booking.

Choose the channel per customer

Run EDI and Peppol side by side without double invoicing

What we recommend.

1. Record one legal invoice channel per customer and note it in the customer file (in OrdoGrid, the client's Notes field).
2. Never send the same invoice through two channels. Peppol cannot detect duplicates (FPS specific FAQ, question 4), and on 8 September 2026 the Belgian Peppol service providers' forum recommended sending only via Peppol when the recipient receives there.
3. Send a credit note in the same format as the invoice it corrects, and through the same channel. For a structured invoice the same format is a legal requirement (art. 53 §2bis, al. 3 VAT Code) and the same channel is our recommendation; a credit note for an invoice issued before 2026 has no format requirement.
4. Keep Peppol receiving active even if all your customers use EDI: your Belgian suppliers will send their invoices to your Peppol registration.
5. If some invoices are issued from another system, give them their own number series. Numbering may be based on one or several series, each sequential and unique (art. 5 §1, 1° Royal Decree no. 1).

In OrdoGrid: Peppol, not EDI

What OrdoGrid does. OrdoGrid connects to Peppol through a certified access point. It does not offer EDIFACT, AS2, VAN connections or uploads to buyer portals: it produces the UBL file only for a Peppol send, and its emails carry the PDF without XML. Peppol sending requires a company with a BE VAT number and a signed Autorisation Peppol (Peppol authorisation). Many labels stay French in every interface language. The complete first send is in send your first Peppol invoice.

To check whether a customer that asks for EDI can receive on Peppol, and to send it the invoice:

1. In Clients, open or create the client with its N° de TVA (VAT number). If the customer requires a purchase order, tick Exiger un bon de commande pour les factures (require a purchase order for invoices). There is no Peppol ID field: OrdoGrid finds the customer from its VAT number when you send.
2. Create the invoice with Nouvelle facture (new invoice) and enter the order number in N° bon de commande (purchase-order number). OrdoGrid sends it as the buyer reference (BT-10); Peppol BIS requires a buyer reference or an order reference on every invoice (rule PEPPOL-EN16931-R003). OrdoGrid has no separate order-reference field (BT-13): if the buyer matches invoices to orders only on BT-13, agree with it that it reads BT-10.
3. Click Envoyer (send). During Vérification de l'éligibilité... (checking eligibility) OrdoGrid looks the customer up; when it is found, Envoi électronique via Peppol (electronic sending via Peppol) is ticked.
4. Untick Email unless the customer asked for a copy, then click Sauvegarder & Envoyer (Save & Send).
5. Follow the send in Peppol → Outbox. Traité (processed) means network delivery, not acceptance. If the customer sends an Invoice Response and OrdoGrid holds your reception, it appears with the invoice.

If the window shows Peppol — ignoré (skipped) with Le client n'est pas enregistré sur le réseau Peppol (client not registered on Peppol), check the VAT number with the customer and look up 0208: plus its enterprise number on lookup.peppol.org before you use the fallback.

Receiving when your EDI provider has already registered you. Reception of a Peppol document type can sit with only one provider at a time. If your EDI or ERP provider has registered you, Réception Peppol (Peppol reception) shows Déjà inscrit sur le réseau Peppol (already registered on Peppol): choose Continuer en envoi seul (continue send-only) and keep receiving there. In send-only mode, the Invoice Responses that customers send about your OrdoGrid invoices are also routed to that registration, so they arrive at your other provider, not in OrdoGrid: check them there. To move reception to OrdoGrid, the current provider must deregister you first, because OrdoGrid does not support the Peppol migration-key procedure. When you click Activer la réception (activate reception), OrdoGrid registers 0208: plus your enterprise number, including the self-billing document types, and Peppol → Statut shows your Identifiant Peppol (Peppol identifier).

What to do for an agreed EDI channel. If you and a customer agree on UBL or CII over its EDI channel, OrdoGrid cannot deliver it. Issue that customer's invoices from your EDI provider's tool, in a separate number series, and do not also send them from OrdoGrid.

Worked example: a retailer that asks for EANCOM invoices

Cartonnages Lemaire SRL, a packaging maker in Mouscron, invoices 38 Belgian business customers on Peppol from OrdoGrid. In September 2026 it wins a contract with Bouwmarkt Verhaegen NV, a DIY chain in Mechelen. Verhaegen's supplier handbook, written in 2019, says orders go out as EANCOM ORDERS messages and invoices must come back as EANCOM INVOIC messages (EDIFACT, directory D96A), both over its VAN.

1. Check the buyer. Lemaire's office manager enters 0208: and Verhaegen's enterprise number on lookup.peppol.org and finds it registered to receive Peppol BIS Billing invoices and credit notes. She saves a dated screenshot.
2. Classify the flow. EANCOM INVOIC is EDIFACT, so it cannot be the legal invoice for this Belgian customer, with or without an agreement. Verhaegen's accounts payable confirms by email that invoices and credit notes will come on Peppol only, from the first invoice, with no PDF or EDIFACT copy. Orders keep arriving over the VAN; the law does not cover them.
3. Send the invoice. The first delivery is invoiced as F-2026-0318, dated 5 October 2026 and due 4 November 2026, with Verhaegen's order number 4500098812 in N° bon de commande.

The total including VAT, and the amount due, is €6,969.60. EN 16931 computes VAT on the 21% category total: 21% × €5,760.00 = €1,209.60. OrdoGrid validates the file before delivery, so €5,760.00 + €1,209.60 must equal €6,969.60 exactly. A few minutes after Sauvegarder & Envoyer, the Peppol → Outbox row shows Traité. OrdoGrid sends 4500098812 as the buyer reference (BT-10); it has no separate order-reference field (BT-13). Before the first send, Verhaegen's accounts payable confirmed to Lemaire's office manager that it matches Peppol invoices to orders on BT-10, so the invoice is matched to its EDI order without retyping.

4. Correct with a credit note. On 9 October Verhaegen reports 100 display trays damaged in transit. Lemaire selects F-2026-0318 in the Factures (invoices) list and clicks Note de crédit (credit note). OrdoGrid prefills every line of the invoice, so the shipping-box line is deleted and the display-tray quantity is set to 100. Credit note NC-2026-0027 covers 100 × €4.20 = €420.00 plus €88.20 VAT, €508.20 in total, and refers to F-2026-0318. Lemaire's accountant confirms that art. 79 of the VAT Code applies, and OrdoGrid adds the mention ‘T.V.A. à reverser à l'Etat dans la mesure où elle a été initialement déduite’ (Royal Decree no. 4, art. 4 §1) itself, because the credit note refunds Belgian VAT to a customer with a VAT number. The credit note goes on Peppol like the invoice. The amount outstanding on F-2026-0318 falls to €6,969.60 − €508.20 = €6,461.40.
5. The variant. Had Verhaegen insisted on its VAN, the only compliant option would have been a written agreement on an EN 16931 invoice in UBL 2.1 or CII D16B over that VAN, with both companies still able to use Peppol. Lemaire would then have issued Verhaegen's invoices from its EDI provider's tool in a separate series, for example V-2026-0001, and not from OrdoGrid.

Edge cases and common mistakes

Evidence to keep

What the law requires. Keep the invoices you issue and receive 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 of origin, integrity and legibility guaranteed for the whole period. Keeping the original XML is not mandatory, but FPS Finance strongly recommends it.

What we recommend.

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. OrdoGrid is not a legal archive and guarantees no retention period.

FAQ

My retailer demands EDIFACT invoices. Am I compliant?

Not if the retailer is a business established in Belgium: EDIFACT is not on the EU syntax list, so it cannot carry the legal invoice, even with an agreement. Send Peppol BIS, or agree in writing on an EN 16931 invoice in UBL or CII over its EDI channel.

Is Peppol just another kind of EDI?

Technically it is structured exchange between systems, but over an open network with shared identifiers, transport (AS4) and rules, which you join through a single certified provider of your choice. In Belgium it is also the legal default for B2B invoices.

Can my customer force me to use its EDI network or portal?

Not unilaterally. The default is Peppol BIS; another format or channel needs both parties' agreement, and FPS Finance says a portal needs your clear written consent. A supplier contract can still create commercial pressure, so negotiate its invoicing clause.

Can we keep EDI for orders and despatch advices?

Yes. The obligation covers invoices and the credit and debit notes that correct them. Orders, despatch advices and other messages can stay on EDI.

If we agree on UBL over AS2, do we still need Peppol?

Yes. Art. 13quater of Royal Decree no. 1 requires the technical means to issue and receive Peppol BIS even when another format is agreed. Lacking them is fined €1,500 for a first infringement, €3,000 for a second and €5,000 for each further one.

Can my EDI provider and OrdoGrid both handle our Peppol traffic?

Sending can run from several tools. Receiving a document type can sit with only one provider; in OrdoGrid, choose Continuer en envoi seul (continue send-only) if another provider holds your registration. Invoice Responses to your invoices then go to that provider.

Can OrdoGrid send EDIFACT or upload to a buyer portal?

No. OrdoGrid sends Peppol BIS through a certified access point and emails PDFs. It creates no EDIFACT files and has no AS2, VAN or portal connection.

Does Traité in the Outbox mean the buyer accepted the invoice?

No. It confirms network delivery. Only an Invoice Response, optional in standard Peppol, gives the buyer's decision, such as AP (accepted) or RE (rejected).