ASBL and VZW invoicing in Belgium: VAT status, invoices and Peppol

A Belgian ASBL (association sans but lucratif) or VZW (vereniging zonder winstoogmerk) invoices because of what it supplies and how VAT treats each supply, not because of its legal form. Membership contributions, gifts and grants rarely lead to a VAT invoice. Hiring out the hall to a company for a day, giving a sponsor publicity or selling services to businesses can make the association a taxable person with invoicing duties and, since 1 January 2026, Peppol duties.

This guide is for boards, treasurers and their accountants. It helps you classify the association and each paid activity, choose the right document and set up OrdoGrid. It does not settle your VAT status: get that from your accountant, in writing. The Peppol duties of every VAT regime are compared in Peppol duties for franchise, VAT-exempt and flat-rate businesses.

Step 1: identify your association's VAT status

What the law requires. An ASBL is a taxable person only to the extent that it carries out an economic activity. Since 1 January 2026, art. 53 §2bis of the VAT Code requires a taxable person established in Belgium to issue a structured e-invoice, on Peppol by default, for its supplies to taxable persons established in Belgium that give a Belgian VAT number, except supplies exempt under article 44, and to be able to receive structured e-invoices. FPS Finance, the federal tax administration, confirms that businesses making only article 44-exempt supplies have neither duty, and the obligation does not apply between two parties when one is not a taxable person (FPS scope page). General rules: the Belgian e-invoicing obligation.

Look up the association in the KBO/BCE public search (Crossroads Bank for Enterprises). Under "Characteristics", "Subject to VAT" with a start date means it has a VAT number: BE followed by its enterprise number. Without that line it is not identified for VAT; if it makes taxed supplies anyway, see your accountant first.

An association that must issue and receive but lacks the technical means risks a fine of €1,500, then €3,000 and €5,000 for further infringements (Royal Decree no. 44, as amended by the Royal Decree of 8 July 2025).

Article 44 exemption

An exemption tied to the nature of the supply, listed in article 44 of the VAT Code: certain social, educational, sports, cultural and medical services, and in principle the letting of immovable property. It is not the small business franchise, which depends on turnover. Since 1 January 2026, these supplies need no VAT invoice (art. 53 §2).

Step 2: classify each paid activity

List everything the association is paid for and settle each line with your accountant. The middle column says where an activity usually lands or which question decides it.

A taxed supply to a legal person without a VAT number, such as another ASBL, still needs an invoice, but a PDF or paper one: it is outside the structured e-invoice obligation.

Hall hire: the six-month rule

The letting of immovable property is exempt under article 44 §3 2° of the VAT Code. Since 1 January 2019 (Law of 14 October 2018, art. 5), making a building available other than as housing for at most six months is taxed. The short hire stays exempt when the user is:

• a natural person using the hall for private purposes, or more generally outside an economic activity;
• an organisation without profit motive;
• a person who uses the hall for operations exempt under article 44 §2.

So the same hall can produce taxed and exempt hires in one week: the tenant and the use decide, not the room. Record on each booking the tenant, the use and the dates. When a hire includes substantial services, such as catering, technicians or equipment, ask your accountant whether the package is still a letting.

Public bodies as customers

Selling to a commune, a CPAS/OCMW, a region or a community under a public contract brings a public-procurement duty: e-invoicing is compulsory for contracts published after 1 March 2024, in principle from €3,000 excluding VAT, and federal authorities require it below that too (FPS Finance, B2G). The buyer's KBO/BCE entry shows "Contracting authority". Public buyers receive through Mercurius, the public-sector Peppol mailroom of FPS BOSA. Without a Belgian VAT number you cannot send on Peppol from OrdoGrid. As of October 2026 you can enter the invoice on the Mercurius portal with an eID, but FPS BOSA has announced that Mercurius moves to a new platform at the end of 2026, so check the current procedure first. Details: Mercurius and B2G invoicing.

Step 3: set up OrdoGrid for your status

OrdoGrid connects to Peppol through a certified access point, for companies with a Belgian VAT number only. Owners and administrators edit Profil entreprise (company profile) and create and send documents.

No VAT number, or only article 44-exempt supplies

1. In Profil entreprise, enter the name with its legal form in Nom de l'entreprise, for example 'Les Amis du Jazz ASBL', and the registered seat in Adresse, Code postal, Ville and Pays. With a seat in the Dutch-language area, set Langue des documents (document language) to Dutch: the legally mandatory parts of invoices must be in Dutch there (Flemish decree of 19 July 1973).
2. Leave Numéro de TVA (Optionnel) (VAT number) empty if you have no VAT number: the PDF prints this field as your VAT number, so an enterprise number typed there misstates your status. The Peppol pages then show Numéro de TVA requis (VAT number required), which is fine without a Peppol duty.
3. For membership fee requests and other payments that need no VAT invoice, use Demandes de paiement → Nouvelle demande (payment request). Set the TVA rate of every line to 0% (new lines start at 21%). If Options de TVA is shown, keep Traitement TVA on Standard: when the lines are already at 0% as you pick a client outside the EU or, if you have a VAT number, a business in another EU country, OrdoGrid switches it to Export or Autoliquidation, and that text prints on the PDF. A payment request needs your IBAN, carries a SEPA QR code and goes out by email with Envoyer.
4. With Starter or Business, when the money arrives, turn it into a receipt with the row button Reçu, or use Reçus → Nouveau reçu (receipt) for a payment received without a request, again with every line at 0%. Neither goes over Peppol.

Mixed, franchise or fully taxed association

1. In Profil entreprise, also enter Numéro de TVA (Optionnel): BE followed by the enterprise number.
2. Open Peppol. On Autorisation Peppol (Peppol authorisation), enter the Nom complet du signataire (signatory's full name), tick the confirmation and click Signer et confirmer l'autorisation. It is a typed confirmation, not a qualified electronic signature; we recommend that a person who may represent the association signs.
3. On Réception Peppol, if the page shows Pas encore trouvé sur le réseau Peppol (not yet on Peppol), click Activer la réception: OrdoGrid registers you as 0208: plus your enterprise number. If it shows Déjà inscrit sur le réseau Peppol, another provider receives for you: click Continuer en envoi seul (send only), or have it deregister you first. If it shows Référencé sur Peppol, access point non vérifié (listed on Peppol, access point not verified), Activer la réception tries to register you and is refused if another provider holds your identifier. Check Peppol → Statut: Réception (Inbox) should read Enregistré.
4. For a taxed supply, click Nouvelle facture, choose the customer with Sélectionner un client, add lines with Ajouter un article at the right TVA rate and keep Traitement TVA (VAT treatment) on Standard under Options de TVA.
5. Click Envoyer, keep Envoi électronique via Peppol ticked and click Sauvegarder & Envoyer (save and send). In Peppol → Outbox, Traité means delivered on the network, not accepted or paid.
6. Under the franchise, choose Régime de la franchise de taxe. On French and Dutch documents, OrdoGrid prints the official 'Régime particulier de la franchise de taxe' or 'Bijzondere vrijstellingsregeling van belasting'; English and German documents carry a translation. See small business VAT exemption: invoicing.
7. Supplier invoices arrive in Peppol → Inbox, marked NOUVEAU. Reject one not meant for you with Répondre, code RE Rejetée and a reason code. OrdoGrid does not book them: each month, select that month's Inbox documents and download them as a ZIP for your accountant. More in set up Peppol in OrdoGrid.

Company-law mentions on every document

Article 2:20 of the Companies and Associations Code applies to every legal person, ASBL and VZW included: invoices, letters, orders and websites show the name, legal form, precise seat address, enterprise number, 'RPM' or 'RPR' (register of legal persons) with the court of the seat, and email and website where applicable. Name, seat and email come from Profil entreprise; put the rest in its field Mentions légales (pied de page des factures), for example 'ASBL – enterprise number 0418.765.232 – RPM Liège – www.culturehouse.be', and check it with Aperçu du PDF (PDF preview). That text prints in the footer of invoices, credit notes, payment requests, receipts and quotes, and travels in Peppol invoices as the seller's additional legal information (BT-33). Full list: Belgian invoice legal mentions.

Worked example: Culture House ASBL in Liège, September 2026

Culture House ASBL (enterprise number 0418.765.232, seat in Liège) runs workshops and exhibitions that its accountant classified as exempt under article 44. It also hires out its hall, so it is identified for VAT as BE 0418.765.232 under the normal regime, a mixed taxable person. It activated reception in OrdoGrid: Peppol ID 0208:0418765232.

1. Taxed invoice. The hire ended on 24 September, so the invoice must be issued by 15 October 2026 (Royal Decree no. 1, art. 4). One line, 'Hall hire, Thursday 24 September 2026, 08:00–18:00', 1 × €650.00 at 21% gives €136.50 VAT, with the company-law line in the footer, from Mentions légales (pied de page des factures). OrdoGrid finds Studio Berg on Peppol; after Sauvegarder & Envoyer, the Outbox shows Traité.
2. Exempt hire. No VAT invoice is required. The payment request has one line at 0%, and its Notes read 'Hall hire, 26 September 2026 – exempt from VAT, letting of immovable property (art. 44 §3 2° VAT Code)', and the booking form records that the tenant is an ASBL.
3. Purchase. The treasurer checks the printer's invoice in the Inbox and pays €580.80 with the QR code in its Paiement block. As the posters serve taxed and exempt activities, the accountant decides how much of the €100.80 VAT is deductible.

Variants. If Studio Berg were not on Peppol, OrdoGrid would show Peppol — ignoré with Le client n'est pas enregistré sur le réseau Peppol: email the PDF, which is a valid invoice, and keep a dated screenshot. Under the franchise, F-2026-0047 would show €650.00 with no VAT and 'Régime particulier de la franchise de taxe', still on Peppol, and none of the €100.80 could be deducted (art. 56bis §4). A cancelled hire is corrected with Note de crédit from the invoice, which also goes over Peppol.

Edge cases and common mistakes

Evidence to keep

• The KBO/BCE extract showing the VAT status, the VAT identification letter and, under the franchise, the notification.
• Your accountant's written classification of each activity.
• For each hall hire: the booking with the tenant's name, enterprise number if any, use and dates. For exempt short hires, we recommend a signed statement that the use is private or that the tenant is a non-profit organisation.
• Grant decisions and reports, sponsorship agreements.
• With Peppol duties: Peppol → Statut showing Réception (Inbox) as Enregistré with its "Depuis le" (since) date, the XML and PDF from Peppol → Outbox, and a ZIP of each month's Inbox documents.

Keep invoices for 7 years from 1 January of the year after issue (VAT Code art. 60, as amended by the Law of 18 December 2025). OrdoGrid stores the documents it exchanged but is not a legal archiving service.

FAQ

Must a Belgian ASBL or VZW issue invoices?

Yes, for taxed supplies to businesses and other legal persons, by the 15th of the following month, as a structured e-invoice when the customer is established in Belgium with a Belgian VAT number. Article 44-exempt supplies and payments that buy nothing, such as most gifts, need no VAT invoice.

Our ASBL has no VAT number: must suppliers send us Peppol invoices?

They need not: the B2B obligation covers only customers established in Belgium that must give a Belgian VAT number, so PDF or paper is fine. A voluntary Peppol registration counts as agreement to receive structured invoices, but OrdoGrid can register only associations with a Belgian VAT number.

Do we need a separate Peppol ID?

No. Belgian participants are registered under scheme 0208 with their enterprise number, as OrdoGrid does when you click Activer la réception, and FPS Finance tells suppliers not to ask for a Peppol ID (FAQ B2B Q15).

Is hiring out our hall subject to VAT?

It depends on length, tenant and use. Up to six months for a business's economic activity, it is taxed at 21%; for a private party, a non-profit tenant or article 44 §2 activities, it is exempt; longer lettings are exempt in principle.

Are membership fees subject to VAT or to the Peppol obligation?

Only if the fee is the price of a supply, which depends on what members receive: ask your accountant. Fees from private members never need a structured invoice.

Does a franchise association have to use Peppol?

Yes. It sends structured invoices to Belgian VAT-registered business customers, with the mention 'Régime particulier de la franchise de taxe' or 'Bijzondere vrijstellingsregeling van belasting' in place of VAT, and must be able to receive.

How do we invoice a commune or another public body?

Under a public contract published after 1 March 2024, in principle from €3,000 excluding VAT, electronically: on Peppol from OrdoGrid if you have a Belgian VAT number, otherwise, as of October 2026, on the Mercurius portal with an eID (Mercurius moves to a new platform at the end of 2026).

Can OrdoGrid issue an invoice for an article 44-exempt service?

Yes: choose Exonération (art. 44 CTVA) as the VAT treatment; the lines go to 0% and the invoice prints 'Exonération de TVA – article 44 du Code de la TVA' (Dutch documents: 'Vrijstelling van btw – artikel 44 van het Btw-Wetboek'). No VAT invoice is required, so a payment request or receipt with its lines at 0% and the exemption in Notes also works.