e-Invoicing in Belgium [2025 Requirements]

Who is obliged to use e-invoicing

Who is obliged to use e-invoicing in Belgium?

Belgium has already introduced mandatory e-invoicing for B2G transactions. All Belgian public bodies are already obliged to be able to receive and process electronic invoices in the context of public procurement, which makes it mandatory for all federal government suppliers to issue electronic invoices (transposition of Directive 2014/55/EU). This obligation applies to contracts above EUR 30,000, and from October 2023 it also covers contracts below this amount. Invoices with amounts below EUR 3,000 are exempt from electronically sending.

Archiving requirements for e-invoicing

Is e-invoicing mandatory for B2B?

Currently, B2B e-invoicing is possibly provided when both parties, the seller and the buyer, agree to it. However, measures to reform the tax system, including the invoice exchange model and the transition to electronic invoicing, already started. The Belgian Ministry of Finance has announced that the reforms will focus on electronic invoicing in the private sector in B2B transactions. The main focus will be on reporting data from invoices. PEPPOL is likely to be the preferred standard for e-invoicing, which will include near-live e-reports to replace the annual customer inventory report.

Despite the planned implementation of mandatory electronic invoicing in 2024 due to the legislative impasse around comprehensive tax reforms in Belgium, and given the complexity of the Belgian legal framework, the implementation of e-invoicing was postponed to 2026.

E-invoicing implementation timeline

October 2022 – Mandatory B2G e-invoicing for public contracts and concessions with a minimum value of EUR 215,000.
April 2023 – Mandatory B2G e-invoicing for public contracts equal to or greater than EUR 30,000.
October 2023 – Mandatory B2G e-invoicing for public contracts and concessions with a value of EUR 30,000 or below.
March 2024 – Mandatory B2G e-invoicing for all taxpayers.
January 2026 – Entry into force of mandatory B2B e-invoicing based on Peppol. The mandate applies to all VAT-taxable entities with a fixed establishment in Belgium conducting B2B transactions, except

1. Taxable persons exclusively performing VAT-exempt transactions under Article 44 of the Belgian VAT Code (e.g. specific medical services, cultural activities);
2. Taxable persons in a state of bankruptcy;
3. Taxable persons applying the flat-rate scheme under Article 56 of the Belgian VAT Code;
4. Transactions involving the supply of goods outside Belgium, where no Belgian Tax ID is required.

January 2028 – The Belgian government introduces a mandatory near real-time e-reporting system for tax purposes.

E-invoicing process description

Since March 1, 2024, federal contracting authorities have also been required to implement electronic invoicing for transactions under €3,000. Beginning January 1, 2026, structured electronic invoicing will become mandatory for almost all B2B transactions conducted by Belgian enterprises subject to VAT. However, this requirement does not apply to goods or services supplied directly to consumers for private use (B2C transactions).

This structured invoicing requirement will generally apply to transactions between two Belgian VAT-liable enterprises, with a few exceptions:

Structured electronic invoices are not required for:

persons subject to VAT who are bankrupt,
businesses conducting exclusively VAT-exempt transactions under Article 44 of the VAT Code,
VAT-liable persons without a permanent establishment in Belgium,
VAT-liable persons are taxed on a flat-rate basis (per Article 56 of the VAT Code, which is set to expire by January 1, 2028).

Additionally, there is no obligation to be able to receive structured electronic invoices for:

enterprises conducting exclusively VAT-exempt transactions as specified in Article 44 of the VAT Code.

In general, if a transaction is VAT-exempt under Article 44 of the VAT Code, there is no requirement to send or receive structured electronic invoices.

Why is Comarch the best choice?

We have 20+ years of experience in carrying out various EDI, e-invoicing, and other document exchange projects around the world. In those years, we have successfully connected more than 130,000 entities from over 60 countries.

1. Legal compliance
Full compliance with the latest data exchange regulations and modern data transfer standards
2. Digitization
Applying new technologies and IT solutions in order to streamline workflows and automate activities and procedures
3. Individual approach
Tailor-made solutions based on processes specific to each company – own road map and a suitable pace of changes
4.Security
Highest level of security for all sensitive and important company data

Achieve Global e-Invoicing Compliance with Comarch

Make sure your business meets international standards with the Comarch e-Invoicing platform, trusted in more than 60 countries. Enjoy hassle-free integration and continuous compliance updates.

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