Self-billing in Belgium on Peppol
When the customer issues the invoice for the supplier: written agreement, who appears as seller and buyer, who sends on Peppol, and common pitfalls for Belgian SMEs.
Updated
- Belgium
What self-billing means
In self-billing, the customer draws up the invoice for goods or services received from the supplier, under a prior agreement. Peppol only carries the structured file. The commercial and VAT setup must already be clear.
This does not replace your agreement or accountant review. Ordinary document roles: Invoice, credit note, and quote.
Agreement first
Belgian practice expects a written self-billing agreement before these invoices circulate. Align at least on:
| Topic | Why |
|---|---|
| Scope of goods or services | Avoid self-billing random purchases |
| Accept / dispute window | Supplier can reject a wrong self-bill |
| Invoice numbering | Who owns the number sequence |
| VAT treatment | Mentions and tax treatment match the supply |
| Peppol channel | Who sends, which IDs, who archives the original |
Without that agreement, a structured file from the buyer is a workaround, not controlled self-billing.
Who issues, who sends
| Question | Practical answer |
|---|---|
| Who prepares the invoice? | The customer (buyer), under the agreement |
| Who is the supplier on the invoice? | Still the real supplier of the goods or services |
| Who is the customer on the invoice? | Still the buyer who received the supply |
| Who may send on Peppol? | Often the buyer (or their provider), acting under the agreement |
Sending the file is not the same as being the supplier. Do not swap names to make a normal sales invoice "fit". That breaks VAT evidence and matching.
Practical workflow
- Sign or renew the self-billing agreement; store it with master data.
- Confirm both Peppol identities and who will send.
- Keep supplier and customer parties correct; include required legal mentions.
- Use your tool's self-billed invoice option, not a normal sales invoice labelled in a footnote.
- Give the supplier a clear accept/reject path (process email or buyer responses if you use them).
- Correct errors with a self-billed credit note pattern, not by editing a delivered invoice (credit notes on Peppol).
For in-scope domestic B2B under the 2026 obligation, self-billing still needs a valid structured document when Peppol is the exchange path.
Common pitfalls
- No written agreement
- Buyer listed as supplier because they clicked Send
- Normal invoice type used while calling the flow "self-billing"
- Supplier has no way to reject a wrong self-bill
- PDF-only archive of a structured self-bill