Self-billing in Belgium on Peppol: agreement, acceptance and setup

Self-billing (autofacturation in French) means your customer draws up and issues the invoice for the goods or services you supply, in your name and on your behalf. You remain the seller and the VAT treatment does not change: you report the sale and, unless the customer owes the VAT under reverse charge, the VAT. Belgian law allows it only with a prior agreement and an acceptance procedure for each invoice. Since 1 January 2026, a self-billed invoice within the Belgian B2B e-invoicing obligation must be structured; on Peppol it travels as a separate self-billing document type that you, the supplier, must be registered to receive.

This guide is for suppliers whose customers draw up their invoices (a retailer that counts your deliveries, a platform that calculates your commission), for buyers considering self-billing, and for their accountants. For the obligation in general, see the Belgian B2B e-invoicing obligation; for credit notes you issue yourself, see credit notes on Peppol.

Who does what in a self-billing arrangement

The two legal conditions

A customer may issue a structured e-invoice for its supplier only if there is a prior agreement between both parties and each invoice is subject to an acceptance procedure by the supplier (art. 53 §2bis of the VAT Code, inserted by the Law of 6 February 2024). FPS Finance, the federal tax administration, confirms in its B2B FAQ (question 10) that these rules are unchanged and that self-billing is possible via Peppol.

Neither the law nor the FAQ prescribes a form. The European Commission's explanatory notes on the EU invoicing rules (non-binding, note B-4) say the parties set the terms, “prior” means agreed before the first self-bill, and the parties must be able to show the agreement existed. Acceptance may be explicit or implicit: described in the agreement, or shown by the supplier processing the invoice or receiving payment. If you rely on tacit acceptance (a self-bill counts as accepted unless disputed within five working days, for example), write it into the agreement and confirm it with your accountant.

What to put in the agreement

Our recommendation, not a legal template:

What a self-billed invoice must show

A self-billed invoice is a full VAT invoice: every mention of art. 5 §1 of Royal Decree no. 1 applies, with your details as supplier (full list: legal mentions on Belgian invoices). Points to watch:

• Parties. Your name, registered office address and VAT number as supplier; the customer's as customer, even though the customer sends it.
• The self-billing mention. “Autofacturation” (French) or “factuur uitgereikt door afnemer” (Dutch), required when the customer issues the invoice in the name and on behalf of the supplier (art. 5 §1 9°ter). The EU VAT Directive's English text says “Self-billing” (art. 226, point 10a). We have not verified an official German wording: for self-bills in German, ask your accountant.
• Your VAT treatment. Rates (21%, 12% or 6%) and the VAT total in euro, as on your own invoices. Under reverse charge, “Autoliquidation” or “Btw verlegd” replaces them (9°bis). Under the small-business franchise, no VAT and the mention “Régime particulier de la franchise de taxe” or “Bijzondere vrijstellingsregeling van belasting” (10°quater).
• Number. Sequential and unique, “based on one or several series” (art. 5 §1 1°). The Commission's notes accept a separate series per customer, including for self-billed invoices. In practice the customer keeps a series per supplier, such as AF-ZUID-2026-0038, which never collides with your own F-2026-… series (invoice numbering).
• Dates. The issue date, and the date or period of supply when it differs (5°). The deadline is the ordinary one: the 15th of the month following the chargeable event.
• Format. Within the 2026 obligation, a structured e-invoice; a PDF copy is optional.

How self-billing travels on Peppol

Peppol has a separate specification for self-billing, Peppol BIS Self-Billing 3.0, alongside the Peppol BIS Billing 3.0 used for ordinary invoices. FPS Finance confirms the separate document type, that the supplier is the one who registers to receive it, and that prior agreement and acceptance of each document still apply (specific FAQ, question 22).

In practice:

• Your registration decides delivery. Your customer can only deliver self-bills if your Peppol ID is registered for the self-billing invoice and credit note. Check at lookup.peppol.org with 0208: and your enterprise number.
• No Peppol acceptance message yet. As of October 2026, the Belgian Peppol service-provider forum notes that status reports (Invoice Responses) for self-billing are reportedly not possible and that a change request has been filed. Run the acceptance procedure outside Peppol, as agreed.
• Manual review is allowed. Automatic processing of self-bills is not a legal obligation (B2B FAQ, question 23).

Which situation are you in?

In OrdoGrid: receive self-bills as a supplier

What OrdoGrid does. OrdoGrid connects to Peppol through a certified access point. Activating reception registers 0208: plus your enterprise number for BIS Billing invoices and credit notes, Invoice Responses, Message Level Responses, and the self-billing invoice and credit note.

What it does not do. It does not issue self-billed documents and has no acceptance workflow for them. It also does not show self-bills addressed to you: OrdoGrid assigns each received invoice or credit note to a company by the buyer's VAT number, and in a self-bill you are the seller, so the document is not matched to your company and does not appear in your Inbox. Your customer's software can still show it as delivered, because activating reception registers the self-billing document types. Until OrdoGrid support confirms otherwise, agree that the customer also sends you each self-bill as a PDF and XML copy, and run acceptance from that copy.

1. Open Peppol. If you are redirected to Autorisation Peppol (Peppol authorisation), enter the Nom complet du signataire (signatory's full name), tick the confirmation and click Signer et confirmer l'autorisation (sign and confirm). This is a typed declaration, not a qualified electronic signature.
2. On Réception Peppol (Peppol reception), click Activer la réception (activate reception). If the page shows Déjà inscrit sur le réseau Peppol (already registered on Peppol), another provider already receives Peppol documents for you: ask it whether your registration includes the self-billing document types, since only one provider can receive a document type for you.
3. On the Statut (status) tab, under Annuaire Peppol (Peppol directory), copy your Identifiant Peppol (Peppol identifier) into the agreement.
4. Check lookup.peppol.org with 0208: and your enterprise number: the self-billing invoice and credit note should be listed. Keep a dated screenshot.
5. Before the first self-bill, contact OrdoGrid support. Check each self-bill from the PDF and XML copy your customer sends you; do not wait for it in Inbox.
6. Accept or dispute each self-bill through the channel in the agreement, not with Répondre (reply with an Invoice Response): Peppol status messages for self-billing are not available yet.
7. Do not also invoice the same supplies with Nouvelle facture (new invoice). Supplies outside the agreement go out as usual: click Envoyer (send), make sure Envoi électronique via Peppol (electronic sending via Peppol) is ticked, then click Sauvegarder & Envoyer (save and send).
8. Give the self-bills (the copies your customer sent) to your accountant, who records them as sales invoices. Self-bills do not appear under Factures (invoices), so Record payment does not apply to them: track their payment in your accounting software or bank reconciliation instead.

If you are the buyer

Worked example: weekly bread deliveries

Bakkerij Zuid BV in Ghent (VAT BE 0476.543.281, Peppol ID 0208:0476543281) delivers sourdough loaves to the four shops of Supermarkt Noord NV (VAT BE 0412.876.540). Their agreement, signed on 1 July 2026 before the first self-bill, provides for:

• a self-bill every Monday, based on the delivery notes signed in the shops;
• series AF-ZUID-2026-… for self-bills and AFC-ZUID-2026-… for self-billed credit notes;
• Dutch-language documents with “factuur uitgereikt door afnemer”, sent via Peppol BIS Self-Billing to 0208:0476543281, with a PDF and XML copy emailed to Bakkerij Zuid;
• deemed acceptance unless Bakkerij Zuid disputes by email within five working days;
• payment 30 days after the self-bill.

Before starting, Bakkerij Zuid activated reception in OrdoGrid, checked lookup.peppol.org and decided to check each self-bill from the emailed copy, because self-bills do not appear in the OrdoGrid Inbox.

1. Monday 21 September 2026. Supermarkt Noord issues AF-ZUID-2026-0038 for the deliveries of 14 to 19 September: 400 sourdough loaves of 800 g at €2.65 excluding VAT, 6% VAT, sent on Peppol as type 389.
2. Wednesday 23 September. Checking its delivery notes, Bakkerij Zuid sees that on 17 September the Ghent shop refused 20 loaves from a damaged crate, as noted on the signed delivery note. It disputes by email, within the five days, with that note attached.
3. Thursday 24 September. Supermarkt Noord issues self-billed credit note AFC-ZUID-2026-0004 for 20 loaves, referring to AF-ZUID-2026-0038 of 21 September (type 261, with that invoice as billing reference).
4. Friday 25 September. Bakkerij Zuid confirms by email that it accepts both documents.
5. Wednesday 21 October. Supermarkt Noord pays €1,067.42.

400 × €2.65 = €1,060.00, and 6% of that is €63.60; the credit is 20 × €2.65 = €53.00 plus €3.18 VAT. Bakkerij Zuid reports €60.42 of output VAT for these deliveries in its VAT return for the period, with its other sales; Supermarkt Noord deducts the same €60.42. A cake order for a shop anniversary on 26 September is outside the agreement, so Bakkerij Zuid invoices it itself in OrdoGrid, in its own F-2026-… series.

Mistakes to avoid

Evidence to keep

• The signed, dated agreement showing it predates the first self-bill, with annexes, amendments and any suspension or termination.
• For each self-bill and self-billed credit note: the XML, any PDF, the acceptance record (a confirmation, or the dispute period that expired without dispute) and any dispute with its outcome.
• The data behind each self-bill: delivery notes, weighing tickets, sales or commission statements.
• Proof you could receive: a dated lookup.peppol.org result listing the self-billing document types, and a screenshot of your Statut tab.
• Retention: 7 years from 1 January of the year after the invoice date (art. 60 VAT Code, restored by the Law of 18 December 2025), longer for documents linked to VAT revision on immovable property. Keep the XML, not only the PDF. OrdoGrid gives no archiving guarantee, so keep your own copies: see invoice archiving in Belgium.

FAQ

What is self-billing in Belgium?

Your customer draws up and issues the invoice for your supply, in your name and on your behalf. You stay the seller and report the sale and, unless reverse charge applies, the VAT. It needs a prior agreement, an acceptance procedure for each invoice and the mention Autofacturation or factuur uitgereikt door afnemer.

Does the self-billing agreement have to be in writing?

The law requires a prior agreement without prescribing its form. You must be able to show it existed before the first self-bill, so a written, dated agreement signed by both is strongly recommended.

Can acceptance of a self-bill be tacit?

The Commission's explanatory notes say acceptance can be explicit or implicit, agreed in advance or shown by processing or payment. Belgian guidance prescribes no form. Write any deemed-acceptance period into the agreement and confirm it with your accountant.

Who must be registered on Peppol for self-billing?

The supplier. The customer sends the self-billed invoice or credit note, so the supplier must be registered for the self-billing document types.

Can I send self-billed invoices from OrdoGrid?

No. OrdoGrid issues only ordinary Peppol invoices (type 380) and credit notes (type 381) with your company as seller. Use software that supports Peppol BIS Self-Billing, or let your suppliers invoice you.

Can I receive self-billed invoices with OrdoGrid?

Activating reception registers your Peppol ID for the self-billing document types, so the network delivers them to OrdoGrid. But OrdoGrid matches received documents on the buyer's VAT number, so a self-bill in which you are the seller does not appear in your Inbox. Ask your customer for a PDF and XML copy of each self-bill, contact OrdoGrid support before the first one and run acceptance outside OrdoGrid.

Is the self-billing tolerance still in force?

No. It ended on 30 June 2026. The ordinary rules and fines apply, with a waiver only in exceptional cases after an individual analysis.

Is a purchase slip the same as a self-billed invoice?

Not necessarily. Purchase documents for farmers under the special agricultural regime follow Royal Decree no. 22, with their own e-invoicing rules since 1 January 2026. Ask your accountant which regime applies.