Client not on Peppol: what you can and cannot do
Decision tree when a Belgian B2B customer is unreachable on Peppol. Lookup failures, mandate limits, and remediation without fake workarounds.
Updated
- Belgium
When a Belgian B2B client is not on Peppol, PDF-by-email is not the compliant exchange if the mandate applies. Lookup first (scheme 0208), ask them to register and publish receive, keep the structured invoice ready, and document the gap.
One job: decide the next compliant step
Delivery fails because the buyer is not in the Peppol directory, or no Access Point accepts their participant ID. That is a routing failure, not a bad UBL file. For in-scope Belgian B2B under the structured e-invoicing obligation, non-reachability does not erase the duty to exchange structured invoices on Peppol.
Decision tree
Lookup failed?
├─ Wrong KBO/BCE or scheme 0208? → Correct ID, retry lookup
├─ Registered in last hours/days? → Wait for Directory visibility, retry
├─ Branch vs head-office ID? → Confirm legal entity that must receive
├─ Truly not registered? → Ask buyer to register; hold structured send; document attempts
└─ Still failing after registration? → Check they published BIS Billing receive capability
Always verify with a deliberate participant lookup before declaring the client "off Peppol."
| You can | You cannot (when mandate applies) |
|---|---|
| Retry lookup with the correct enterprise number | Treat PDF-by-email as the compliant exchange |
| Ask the customer to complete Peppol registration | Register the customer yourself as if you were their Access Point |
| Email a PDF as interim commercial communication | Claim the obligation paused because delivery failed once |
| Resubmit the structured invoice once they are reachable | Invent a permanent "customer not ready" exemption |
| Log timestamps, IDs tried, and customer contacts | Assume waiting indefinitely replaces structured sending |
What "unreachable" usually means
| Lookup outcome | Likely cause | Action |
|---|---|---|
| No participant | Never registered | Buyer onboarding to Peppol |
| Miss on known VAT number | Typo, old seat, wrong scheme | Fix master data |
| Participant exists, no invoice profile | Send-only or incomplete publish | Buyer must publish invoice receive |
| Intermittent miss after signup | Directory propagation delay | Retry on a schedule; do not switch permanently to PDF-only |
Practical sequence
- Confirm buyer enterprise number (scheme 0208) and legal entity.
- Run participant lookup; capture the error.
- Contact the buyer: registration + receive capability required for in-scope invoices.
- Keep a structured invoice ready; resend when lookup succeeds.
- If commercially urgent, share a PDF and keep the Peppol gap open until structured delivery works. PDF does not close compliance. See PDF versus structured invoice.
- Participant lookup failure
Directory miss that blocks Peppol routing before any invoice content is transmitted.
Worked example
Atelier Nord looks up Studio Berg on 0208:0123456789 and gets no hit. The VAT number on the quote had a transposed digit. After the correction, lookup still fails: Studio Berg never registered. Atelier Nord emails a PDF as interim commercial communication, logs the attempts, and asks them to complete registration with invoice receive. Two days later lookup succeeds; F2026-0118 is sent on Peppol. The PDF did not close the B2B duty.
FAQ
What if my client is not on Peppol?
Confirm the enterprise number, retry lookup, and ask them to register and publish invoice receive. PDF-by-email is not the compliant B2B exchange when the mandate applies.
Can I just email a PDF instead?
As interim commercial communication, yes. As the only original for an in-scope B2B invoice, no.
Can I register the customer myself?
No. They (or their Access Point) must publish their own participant identity.
Is a lookup miss a bad invoice file?
No. It is a routing failure before content is transmitted. Fix identity or publication first.
How long should I wait after they register?
Minutes to hours is common for Directory visibility. Retry on a schedule. Do not switch permanently to PDF-only.
What if they are found but cannot receive invoices?
They published send-only or incomplete receive. Ask them to enable invoice receive, then resend.