If your UK-based company invoices Belgian customers or receives invoices from suppliers based in Belgium, sending a PDF by email used to be enough. Since January 1, 2026, that is no longer the case.
Belgium has made a clear decision: Peppol is now the mandatory channel for all B2B invoices exchanged between VAT-registered businesses established in Belgium. Understanding what this means for your organization is essential to stay compliant with local tax regulations and avoid disputes with your Belgian business partners.
Why Belgium is ahead on e-invoicing
Belgium did not wait for the European Union to mandate e-invoicing before taking action.
As early as 2016, the Federal Public Service Policy and Support (FPS BOSA) was appointed as the national Peppol Authority, making Belgium one of the first European countries to build its e-invoicing ecosystem around the Peppol network.
B2G electronic invoicing for public sector entities had already become mandatory for public procurement contracts published after March 1, 2024.
The B2B mandate, which took effect on January 1, 2026, is the logical next step in this strategy. The law of February 6, 2024, which introduced Article 53 §2bis into the Belgian VAT Code, established the legal framework for mandatory B2B e-invoicing.
Belgium is also aligned with the European ViDA (VAT in the Digital Age) initiative, which aims to roll out real-time digital tax reporting across all EU Member States by 2030. In this area, Belgium is one step ahead of France.
The e-invoicing framework in Belgium
Mandatory requirements since January 1, 2026
All VAT-registered businesses established in Belgium must now use structured electronic invoices for B2B transactions.
This goes far beyond sending a PDF by email. Invoices must be issued, transmitted, and received in a structured electronic format that supports fully automated, end-to-end processing.
The required format is UBL 2.1 (Universal Business Language), an XML syntax that complies with the European EN 16931 standard. A PDF sent by email, even if digitally signed, no longer meets the legal requirements for B2B transactions.
Key exemptions
The obligation does not apply to VAT-registered entities not established in Belgium without a fixed establishment, even if they have a Belgian VAT number. Transactions exempt under Article 44 of the Belgian VAT Code are also excluded.
💡 Important point for UK-based companies: if you do not have a fixed establishment in Belgium and only hold a Belgian VAT identification number, you are not directly required to issue structured electronic invoices. However, your Belgian suppliers are required to send them to you, meaning your systems must be capable of receiving them.
Penalties for non-compliance
Fines of up to €5,000 (£4320) are issued in case of non-compliance. A three-month grace period (January to March 2026) was granted to companies able to demonstrate that they had begun the necessary steps, but this window is now closed. Any PDF invoice exchanged between Belgian VAT-registered businesses is considered non-compliant.
How Peppol works in Belgium
The four-corner model
Peppol is based on a “four-corner” architecture: the sender transmits the document via their Peppol Access Point, which routes it through the network to the recipient’s Access Point, which then delivers it to the end customer. Each company is identified on the network by a unique Peppol ID, usually based on its VAT number.
To fully understand how a Peppol Access Point works and its role in the transmission chain, it is useful to explore it before selecting a technical solution.
Peppol BIS 3.0 standard
Belgium uses the Peppol BIS 3.0 standard, enabling the issuance, reception, and validation of electronic invoices in a structured and automated format.
Peppol is the standard channel for sending electronic invoices in Belgium, but if both parties agree, other exchange methods may be used, provided they comply with EN 16931 standards.
In other words, Peppol is the default and mandatory channel, but two business partners may agree on an alternative interoperable format if both systems support it. In practice, for companies without specific contractual arrangements, Peppol is the default requirement.
The path toward e-reporting in 2028
Belgium will implement an e-reporting system in 2028 based on a five-corner Peppol model, enabling secure and standardised communication between businesses and the tax authorities. This system will replace the annual VAT customer listing declaration.
By adopting Peppol now, companies are laying the foundation for compliance with this upcoming requirement.
What companies must do in practice
#1 – Register on the Peppol network
The first step is to connect to the Peppol network via a certified Access Point. This involves selecting an authorised provider, obtaining a Peppol ID, and configuring your invoicing software to issue and receive UBL-formatted documents.
For French companies preparing for e-invoicing in Belgium, this step is often underestimated in terms of implementation time.
#2 – Check tool compatibility
Not all accounting or procurement software is yet compatible with Peppol. You should verify with your software provider that connectivity is fully operational—not just “in development”. The ability to receive Peppol invoices is often the weak point in companies that overlook this check.
#3 – Train teams and inform partners
The Peppol transition is not just an IT project. Accounting and procurement teams must understand the new workflow:
- How to process incoming XML invoices
- How to handle rejections
- How to follow up with suppliers whose Peppol ID is incorrect
If you have questions about electronic invoicing in this cross-border context, it is useful to centralise them before deployment.
What does this mean for UK-based companies?
Since 1 January 2026, Peppol is the legal standard for B2B exchanges between VAT-registered businesses in Belgium.
For UK companies working with Belgian partners, the challenge is twofold:
- Ensuring their systems can receive Peppol invoices
- Checking whether their situation (fixed establishment, VAT registration) also makes them subject to the obligation to issue invoices.
Key dates for e-invoicing in Belgium
| 1 March 2024 | Mandatory B2G e-invoicing for Belgian public procurement contracts |
| 6 February 2024 | Adoption of the law making B2B e-invoicing mandatory via Article 53 §2bis of the Belgian VAT Code |
| 1 January 2026 | Entry into force of mandatory B2B e-invoicing for all Belgian VAT-registered businesses. End of PDF invoices between companies |
| January–March 2026 | Conditional grace period (subject to proof of compliance efforts) |
| 1 January 2028 | Introduction of near real-time e-reporting based on a five-corner Peppol model, in line with ViDA |
