Construction reverse charge in Belgium: invoice mention and scope

The Belgian construction reverse charge (the cocontractant rule in French, medecontractant in Dutch) moves the VAT on building works from the contractor to the customer. You invoice the works without VAT and the customer declares the VAT in its own return. Since 1 January 2023 the invoice must carry a text prescribed word for word.

This article covers the domestic rule in article 20 of Royal Decree No. 1 (RD no. 1): scope, the mandatory mention, Peppol coding and the steps in OrdoGrid. Reverse charge on services to customers in other EU countries is a different rule: see which Belgian VAT regime changes your invoice.

Cocontractant / medecontractant

The customer (the “contracting party”) that owes the VAT on the works it buys instead of the contractor, under art. 20 RD no. 1. The term names the customer’s role. It is not a VAT exemption.

When the cocontractant rule applies

All three conditions of art. 20 §1–§2 RD no. 1 must be met:

When all three are met, the rule is not optional: the customer owes the VAT and you do not charge it.

Works and operations covered (art. 20 §2)

Customer status: decision table

A private customer pays VAT at the rate for the works: 21%, unless Royal Decree No. 20 grants a reduced rate. Examples are 6% for certain works on private dwellings, such as renovating older homes or, from 1 January 2026 to 31 December 2030, installing heat pumps. Each reduced rate has its own conditions and invoice mention. Check them with your accountant.

Subcontracting chains and mixed jobs

Each invoice in a chain is assessed on its own: what you supply, and to whom.

Do not copy the treatment of the invoice your customer issues further down the chain. If your main contractor bills a homeowner with VAT, you still invoice the main contractor without VAT. A quote can announce that the rule will apply, but the legal mention belongs on the invoice.

The mandatory invoice mention (since 1 January 2023)

Under art. 20 §3 RD no. 1, the invoice shows no VAT rate or VAT amount for these operations and carries this text, in French:

Autoliquidation : En l'absence de contestation par écrit, dans un délai d'un mois à compter de la réception de la facture, le client est présumé reconnaître qu'il est un assujetti tenu au dépôt de déclarations périodiques. Si cette condition n'est pas remplie, le client endossera, par rapport à cette condition, la responsabilité quant au paiement de la taxe, des intérêts et des amendes dus.

or in Dutch:

Verlegging van heffing. Bij gebrek aan schriftelijke betwisting binnen een termijn van één maand na de ontvangst van de factuur, wordt de afnemer geacht te erkennen dat hij een belastingplichtige is gehouden tot de indiening van periodieke aangiften. Als die voorwaarde niet vervuld is, is de afnemer ten aanzien van die voorwaarde aansprakelijk voor de betaling van de verschuldigde belasting, interesten en geldboeten.

What it does. If the customer does not contest in writing within one month of receiving the invoice, it is presumed to file periodic returns. Unless the parties collude, that silence releases you from liability for this condition. It does not cover whether the works fall under art. 20 §2: that stays your responsibility.

Which language. It depends on your seat. In the Dutch-language area, the legally required parts of an invoice must be in Dutch (Flemish decree of 19 July 1973), on pain of nullity. Brussels businesses use French or Dutch. Businesses in the French-language area should check with their accountant which language rules apply. Justel has no consolidated German version of RD no. 1, so no official German text is available there to copy: businesses in the German-language area should agree the language with their accountant. An English translation is not the legal text.

The other invoice details follow art. 5 §1 RD no. 1, and the usual issue deadline applies:

How a Peppol invoice carries reverse charge

Since 1 January 2026, an invoice between two Belgian-established VAT-registered businesses must be a structured e-invoice, by default Peppol BIS. Reverse-charge lines use:

• VAT category AE (“Vat Reverse Charge”, UNCL5305), with line rate 0 (BR-AE-05) and VAT amount 0 in the AE breakdown (BR-AE-09);
• the seller’s VAT identifier and the buyer’s VAT identifier or legal registration identifier (BR-AE-02);
• an exemption reason code or text meaning “Reverse charge” (BR-AE-10).

The FPS Finance asks for extended VAT clauses such as this mention to appear as a document-level note (BT-22) and as the exemption reason (BT-120) (FAQ question 11). Only one document-level note is allowed (PEPPOL-EN16931-R002), so combine all legal texts in it. A customer that receives an invoice stating “autoliquidation” or “reverse charge” without the detailed text should not reject it, but may ask for a correction (FAQ question 27).

What OrdoGrid sends. OrdoGrid connects to Peppol through a certified access point. A Régime cocontractant invoice goes out with category AE, code VATEX-EU-AE, both VAT numbers and the invoice PDF embedded. On Peppol the structured file is the legal invoice; the PDF is only an attachment. The exemption reason (BT-120) carries the mention OrdoGrid prints for this regime, in the document language, and the single document note (BT-22) combines that mention with your Notes; a paragraph repeated word for word appears once. On a French or Dutch document, that mention is the full article 20 §3 text quoted above; English and German documents carry a translation, because no official text exists in those languages (see the table below). Keep the customer’s written confirmation that it files periodic returns.

Issue a cocontractant invoice in OrdoGrid

1. In Clients (Base Clients), open the customer or click Ajouter un client (Add a client). Set Type de client to Assujetti à la TVA (VAT-registered) and enter the N° de TVA. The lookup (badge Registre belge (BCE), the Crossroads Bank for Enterprises) confirms that the number exists, not that the customer files periodic returns.
2. Go to Factures (Invoices) → Nouvelle facture (New invoice) and pick the customer with Sélectionner un client.
3. In the sidebar, open Options de TVA (VAT options) and set Traitement TVA to Régime cocontractant. Every line switches to 0%. These labels follow your document language: “BTW-behandeling” / “Medecontractantregime” in Dutch, “VAT treatment” / “Co-contractor regime” in English, “MwSt.-Behandlung” / “Mitunternehmerregelung” in German.
4. Add lines with Ajouter un article (Add an item): the job, the site, quantity, unit and unit price excluding VAT.
5. Check your document language (Profil entreprise → Langue des documents): in French or Dutch, OrdoGrid prints and sends the full mention above itself, so you do not paste it into Notes. In Notes, keep or replace the default payment text.
6. Click Aperçu du PDF (PDF preview). Check the customer’s VAT number, the full mention and the zero VAT total.
7. Click Envoyer (Send), keep Envoi électronique via Peppol ticked if the customer is found, then click Sauvegarder & Envoyer (Save & Send). Follow it in Peppol → Outbox: Traité means delivered to the customer’s access point, not accepted.

OrdoGrid will not save a Régime cocontractant invoice without both VAT numbers, and refuses to mix it with another VAT treatment on the same invoice. Put normally taxed goods or services on a separate invoice.

Under Régime cocontractant, the PDF prints the mention below the customer details, after the label “TVA :” on a French document, and the Peppol file carries the same text. Which text depends on the document language. For the official wording, use French or Dutch (in the Dutch-language area, Dutch is required anyway):

The suggestion is not a legal check

OrdoGrid never applies Régime cocontractant automatically, even when every line is at 0%. If you keep Standard with 0% lines for a Belgian VAT-registered client, the blocking Erreur de conformité Peppol (Peppol compliance error) dialog offers it under Régime suggéré, with its condition (immovable works for a customer that files periodic VAT returns) and Appliquer ce régime. The dialog only sees that both VAT numbers are Belgian; it does not know what you sell or whether the customer files periodic returns. Apply the regime only after checking the three conditions. Otherwise choose the correct treatment, usually Standard with the applicable rate.

Worked example: works plus separately sold materials

Atelier Nord SRL (Brussels, BE 0712.345.630) finished works in an office building in Anderlecht on 25 September 2026 for Bouwgroep Zuid NV (general contractor in Vilvoorde, BE 0456.789.034, quarterly VAT returns). It also sold spare tiles, delivered to the contractor’s warehouse without laying. In OrdoGrid that means two invoices, dated 2 October 2026 (before the 15 October issue deadline) and due on 1 November 2026.

Invoice F-2026-0142, Régime cocontractant
  Sanitary fittings removed and installed,
  3rd floor, Boulevard Industriel 40, Anderlecht   1 x 5,600.00   5,600.00
  Supply and laying of floor tiles, same site    40 m2 x 60.00    2,400.00
  Taxable amount                                                 8,000.00 EUR
  VAT charged                                                        0.00 EUR
  Amount payable                                                 8,000.00 EUR
  Mention (French document): "Autoliquidation : En l'absence de contestation par écrit, ..."
  Peppol: AE breakdown, taxable 8,000.00, VAT 0.00, VATEX-EU-AE

Invoice F-2026-0143, Standard
  Spare floor tiles, delivered, no installation  30 m2 x 40.00    1,200.00
  VAT 21%                                                          252.00 EUR
  Total                                                          1,452.00 EUR

Bouwgroep Zuid pays €8,000.00 + €1,452.00 = €9,452.00. For F-2026-0142 it declares the VAT in the return for the period in which the VAT became chargeable (art. 20 §4): Q3 2026, since the works were completed in September. At 21% that is €1,680.00 (21% × €8,000.00), deductible to the extent of its right to deduct.

F-2026-0142 showed Traité on 2 October 2026, so the customer could contest its status in writing until 2 November 2026. Charging 21% on the works with the mention would have produced €9,680.00 for the works alone, with wording and amounts contradicting each other.

Edge cases and common mistakes

Evidence to keep

• The order or contract describing the works and site address: it shows why art. 20 §2 applies.
• The customer’s VAT number and, as a recommended practice, its written confirmation that it files periodic returns (for example a clause in the order), or any message saying the opposite.
• The invoice as issued. For Peppol sends, OrdoGrid archives the exact XML and PDF; download them from Peppol → Outbox.
• The delivery date (Traité) or email date: the one-month contest period runs from receipt.
• Any written contest and how you settled it (credit note, new invoice).

Keep invoices seven years from 1 January of the year after issue (VAT Code art. 60, as amended by the Law of 18 December 2025); documents tied to the revision (adjustment) of VAT deductions on immovable property follow longer periods (15 or 25 years). OrdoGrid offers no legal archiving guarantee, so keep your own copy. For the mentions every invoice needs, see mandatory legal mentions.

FAQ

Does construction reverse charge apply to subcontracting?

Yes, when you invoice art. 20 §2 works to a main contractor that files periodic VAT returns. The main contractor’s own invoice to a private homeowner carries VAT.

Is a short or English reverse-charge mention enough?

No. Since 1 January 2023 art. 20 §3 RD no. 1 prescribes a full French text (starting “Autoliquidation”) or Dutch text (starting “Verlegging van heffing”). Without it, the presumption that protects you does not apply.

Is there an official German wording of the mention?

Justel publishes no consolidated German version of Royal Decree No. 1, so this article quotes none. Use the French or Dutch text according to the language rules for your seat. In OrdoGrid, German documents carry a translation; set Langue des documents (document language) to French or Dutch to print the official text.

Can one invoice combine reverse-charge works and goods with VAT?

An invoice can show several VAT treatments, each with its own taxable amount. OrdoGrid accepts only one treatment per invoice with Régime cocontractant, so issue two invoices.

Does the rule apply to private customers or associations?

No. A private individual, or an association that does not file periodic VAT returns, pays VAT on the invoice: 21% unless a reduced rate applies.

What does my customer have to do with the VAT?

It declares the VAT in its return for the period in which the VAT became chargeable and deducts it as far as it is entitled to. If it has not received your invoice by the 15th of the month after the month in which the VAT became chargeable, it must draw up its own document by that date (RD no. 1 art. 9).

What if the customer contests the invoice within the month?

Check its status. If it does not file periodic returns, credit the invoice and issue a new one with VAT. If the dispute is about the works themselves, ask your accountant.