Peppol for Belgian groups: one ID per company, VAT units, mergers

A group can share one finance team and one Peppol provider, but Peppol does not know the group. Every Belgian company that issues or receives in-scope B2B invoices is addressed under its own enterprise number (0208: followed by ten digits), and each invoice travels under the identity of the company that made or received the supply. VAT unit members are no exception: each invoices under its own VAT sub-number.

In OrdoGrid, one login can belong to every group company and switch between them, but each company has its own subscription and plan under Billing & Subscription.

This playbook is for finance teams, controllers and advisers running several Belgian companies: which structure needs which identity, the OrdoGrid setup, intra-group and misaddressed invoices, and mergers. For a single company, follow set up Peppol in OrdoGrid; for the anatomy of an ID and the mod-97 check, see Peppol ID explained.

The rule: one taxable company, one Peppol identity

What the law requires. Since 1 January 2026, a taxable person established in Belgium must issue a structured e-invoice, or have one issued in its name, for supplies made under its Belgian VAT number (or a VAT unit member's sub-number) to a taxable person established in Belgium or to a VAT unit (art. 53 §2bis VAT Code, as amended by the Law of 10 February 2026). Art. 44-exempt supplies are outside. Each in-scope company must also be able to receive, with Peppol BIS over Peppol as the default. Each group company is a separate taxable person unless it belongs to a VAT unit.

What Peppol requires. FPS Finance says every Belgian company on Peppol must be registered at least under its enterprise number, scheme 0208, and that providers are contractually bound to do so. A 0208 value is ten digits starting with 0 or 1, with a mod-97 check; rule PEPPOL-COMMON-R043 rejects an invoice whose 0208 value fails it.

What OrdoGrid does. Each OrdoGrid company has one VAT number, one Peppol authorisation, one reception registration and one Inbox. OrdoGrid refuses a Peppol send when the supplier VAT number on the invoice differs from the active company's, and files each received invoice under the company whose VAT number the supplier entered as buyer.

VAT unit (unité TVA / btw-eenheid)

Persons established in Belgium that are legally independent but closely linked financially, economically and organisationally, treated as one taxable person for VAT (art. 4 §2 VAT Code). The unit files one VAT return under its own number; each member has a VAT sub-number, the only number it shows on the invoices and orders it issues.

Decision table: which structure needs which identity

VAT units: what changes on Peppol

What the law requires.

• On a member's invoices, the supplier details are the member's own (Royal Decree no. 1, art. 5 §1 2°). On contracts, invoices, purchase orders and shipping notes it issues, a member may mention only its own VAT sub-number (art. 30).
• A supply to a VAT unit, where the buying member must communicate its sub-number, is within the structured e-invoicing obligation (art. 53 §2bis, 1° b).
• Supplies between members are outside the scope of VAT. Where no invoice is issued, the supplying member issues a special document (document particulier), and the format conditions of §2bis apply to it where a structured invoice would otherwise have been required (art. 53 §3).
• The representative member files the unit's single VAT return under the unit's own number (CNC opinion 2010/13).

What we recommend. Because each member keeps its own enterprise number and shows only its sub-number to suppliers, register every member that issues or receives invoices under 0208 + its own enterprise number, and tell suppliers to name the member and its sub-number as buyer, never the unit's number.

What OrdoGrid does. Create one company per member with its own sub-number in Numéro de TVA; Activer la réception (activate reception) derives the Peppol ID from those ten digits. Confirm each member's sub-number with your adviser before you activate reception. An invoice naming the unit's number as buyer matches no member company. OrdoGrid has no special-document type for supplies between members.

One provider for all companies, or several?

A provider can host many participant IDs, so the whole group can use the same provider; in OrdoGrid each company still has its own subscription and plan. Each ID can receive with only one provider at a time: a new provider cannot register it until the old one deregisters, unless both use Peppol's migration-key procedure. Sending needs no receiving registration.

Set up the group in OrdoGrid

1. Build the entity register. One row per legal entity: legal name, enterprise number (mod-97 checked), VAT number or sub-number, VAT status, in or out of scope, current receiving provider.
2. Create one company per VAT number. In the profile menu, Créer une nouvelle entreprise (create a new company) opens the company form (Créez une entreprise supplémentaire). Choose Entreprise, type the Numéro de TVA (name and address are prefilled from the Belgian register), complete the steps and click Créer l'entreprise (create the company). The creator becomes owner. Never create a second company for a VAT number already in OrdoGrid.
3. Give access per company. In each company, the owner invites colleagues under Team as Administrator (creates, sends, records payments) or Viewer (read-only). Being administrator of the parent gives no access to a subsidiary. Owners and administrators receive the company's Peppol notification emails.
4. Switch before every action with Changer d'entreprise (switch company) in the profile menu. Documents, clients, the authorisation and API keys belong to the active company.
5. Sign the authorisation. Peppol → Autorisation Peppol: enter the Nom complet du signataire (signatory's full name), tick the declaration, then click Signer et confirmer l'autorisation. It is a typed name and a checkbox, not a qualified e-signature; let someone entitled to commit that company sign.
6. Choose reception. On Réception Peppol, Activer la réception registers 0208: + the enterprise number; Continuer en envoi seul leaves reception elsewhere. Réception déjà liée sur la plateforme (reception already linked on the platform) means another OrdoGrid company with this VAT number holds reception; Ouvrir … (open) takes you there if you belong to it.
7. Check the Statut tab. Envoi (Outbox) reads Autorisé, Réception (Inbox) Enregistré, and Annuaire Peppol → Identifiant Peppol shows the ID for suppliers; its Access point de réception (receiving access point) should read Notre access point (our access point) for a company that receives through OrdoGrid, while Autre prestataire (another provider) means that company's invoices go elsewhere. Confirm it on lookup.peppol.org with 0208: + the number; the lookup proves receiving capability only.
8. Create sister companies as clients in each company that invoices them, using Assujetti à la TVA (VAT-registered business) and N° de TVA (VAT number). Client records are per company.
9. Tell suppliers company by company, each with its own legal name, VAT number and Peppol ID: share your Peppol ID with suppliers.

Worked example: the Nord group

Nord Holding SA owns Atelier Nord SRL (joinery) and Nord Logistics SRL (warehousing); they are not a VAT unit. Nord Holding invoices management fees with VAT to both, so all three are in scope. The group controller, Sofie Peeters, is administrator in all three OrdoGrid companies.

All three pass mod-97: for Atelier Nord, the first eight digits (07123456, i.e. 7,123,456) divided by 97 leave 67, and 97 − 67 = 30, the last two digits.

Intra-group invoice: Atelier Nord supplies packing crates to Nord Logistics

On 28 September 2026, Atelier Nord delivers 40 made-to-measure wooden packing crates to Nord Logistics. The crates are movable goods, not work on a building, so Atelier Nord charges 21% VAT. Both companies are separate Belgian taxable persons, so the invoice must be a structured e-invoice (Peppol BIS over Peppol unless they agree another structured format) issued by the 15th of the following month: 15 October 2026.

1. Changer d'entreprise → Atelier Nord SRL.
2. Factures (Invoices) → Nouvelle facture (new invoice). N° proposes F-2026-0187; Date 5 October 2026; Échéance (due date) defaults to 4 November 2026. Client Nord Logistics SRL, BE 0798.765.405; one line at 21%, VAT option Standard, with Description "Wooden packing crates, delivered 28 September 2026" so the invoice shows the delivery date.
3. Envoyer (send): Envoi électronique via Peppol is ticked because Nord Logistics is on the network. Sofie unticks Email and clicks Sauvegarder & Envoyer (save and send).
4. Peppol → Outbox: the row reaches Traité (processed), meaning network delivery, not acceptance or payment.
5. Changer d'entreprise → Nord Logistics SRL, Peppol → Actualiser (refresh). F-2026-0187 appears in the Inbox with €5,000.00 net. Sofie checks it against the delivery note: Répondre (reply) → AP Acceptée (accepted).

Misaddressed supplier invoice

On 8 October 2026, Scierie Lemaire SRL (BE 0734.567.835) invoices oak boards ordered by Atelier Nord under purchase order AN-2026-044: €2,400.00 + €504.00 VAT = €2,904.00, invoice SL-2026-311. Its clerk picked the wrong customer, so the invoice names Nord Logistics as buyer and lands in Nord Logistics' Inbox.

1. Nord Logistics does not pay, book or deduct it. FPS Finance says an invoice not intended for you should be rejected, for example with code RE (specific FAQ Q28).
2. In Nord Logistics' Inbox: Répondre → RE Rejetée (rejected), reason REC (receiver unknown), note "Ordered by Atelier Nord SRL, BE 0712.345.630, PO AN-2026-044."
3. Scierie Lemaire corrects SL-2026-311 with a credit note to Nord Logistics (Q29) and invoices Atelier Nord anew. The credit note reaches Nord Logistics' Inbox, the new invoice Atelier Nord's.
4. Sofie files the invoice, the response and the credit note together.

Variant: if the Nord companies formed a VAT unit

The crate supply would be outside VAT, so no €1,050.00 VAT. Atelier Nord would issue a special document (or an invoice without VAT), which must still meet the structured e-invoice conditions of §2bis (art. 53 §3 VAT Code). OrdoGrid cannot produce a special document, so Sofie would agree the method with the group's adviser. Scierie Lemaire would still name Atelier Nord's own sub-number as buyer, and Atelier Nord would still receive on 0208:0712345630. The unit's own number would serve its VAT return, not supplier invoices.

Mergers, new companies and other identity changes

Treat each change as a new identity decision, and confirm effective dates and VAT consequences with your adviser.

Edge cases and common mistakes

Integrations: one API key per company

OrdoGrid API keys are company-scoped: a key acts for one company, and no header switches it to another. In each company:

1. Create a key under API keys.
2. Call GET /api/v1/me to confirm which company it addresses.
3. Record the key name (never the secret) in the entity register.
4. Test with one real invoice, as there is no sandbox.

See public API integration.

Evidence to keep

• The entity register, dated and approved by the group controller.
• Per company: a screenshot of the Statut tab (authorisation with "Signé par …", reception, Identifiant Peppol) and the lookup.peppol.org result.
• Each company's message to suppliers, with its date, and your adviser's VAT unit and merger documents.
• Each misaddressed invoice with your RE response and the supplier's credit note.
• Per company, the exchanged XML and PDF (select rows on Peppol, download the ZIP), kept seven years from 1 January of the year after issue (art. 60 VAT Code, as amended by the Law of 18 December 2025).

FAQ

Does each Belgian company in a group need its own Peppol ID?

Yes, if it issues or receives in-scope B2B invoices. Each company is a separate taxable person unless it belongs to a VAT unit, and must be registered at least under 0208 plus its own enterprise number.

Can one access point serve all the companies of our group?

Yes. Each ID receives with only one provider at a time, so a company that keeps another provider uses OrdoGrid send-only.

Can two OrdoGrid companies share one VAT number for receiving?

No. Only one OrdoGrid company per VAT number can hold reception; the second gets Réception déjà liée sur la plateforme.

How should a VAT unit register on Peppol?

We recommend registering each member that issues or receives invoices under 0208 plus its own enterprise number. FPS Finance has no specific rule: confirm with your adviser.

Do invoices between our group companies have to go through Peppol?

Between separate Belgian-established taxable persons, for supplies not exempt under art. 44, the invoice must be a structured e-invoice: Peppol BIS over Peppol by default, unless the two companies agree another structured format. Within one VAT unit, supplies are outside VAT. Where no invoice is issued, the supplying member issues a special document, and it must meet the same structured format conditions (art. 53 §3 VAT Code).

May the parent issue invoices for a subsidiary?

It may issue them in the subsidiary's name, but the subsidiary stays the supplier, with its own name, VAT number and Peppol ID. In OrdoGrid, parent staff work as administrators in the subsidiary's company.

What do we do with an invoice addressed to the wrong group company?

Do not book or deduct it. Reject it with Répondre → RE, naming the right company; the supplier issues a credit note and a new invoice.

What happens to the absorbed company's Peppol ID after a merger?

Keep it receiving for an agreed run-off period, reject misaddressed invoices, then release reception, which deregisters the ID.