Belgium's New Royal Decree on Structured Electronic Invoicing

On July 8, 2025, the FPS Finance issued a new Royal Decree, focusing on the implementation of structured electronic invoicing (e-invoicing) in Belgium. The decree primarily addresses the practical aspects of e-invoicing, establishing technical standards to ensure seamless interoperability and efficiency. 

As from January 1^st, 2026, e-invoicing will become mandatory for all B2B transactions in Belgium. This requirement applies to taxpayers established and VAT registered in Belgium, foreign companies with a fixed establishment in Belgium, and VAT groups. However, certain VAT exempt services under Article 44 of the VAT Code will not be subject to this mandate. This initiative is part of Belgium's efforts to align with the ViDA directive, which aims to modernize VAT systems across the EU, reduce VAT compliance burdens, and combat VAT fraud.

One of the major challenges impeding the widespread adoption of e-invoicing is the lack of interoperability. The decree addresses this by establishing standards for semantics (the content of the invoice), syntax (the format used), and technical interoperability (the transmission methods), ensuring consistent information exchange across various business systems. It mandates the use of Peppol BIS through the Peppol transmission network, ensuring compliance with European standards. The decree allows for some flexibility to use other formats, provided both parties agree to this deviation, and the format complies with EU norms as outlined in Directive 2014/55/EU (EN 16931-1:2017+A1:2019/AC:2020). Despite this flexibility, companies should, however, maintain the capability to use Peppol BIS. Moreover, the adoption of Peppol BIS aligns with future national e-reporting obligations, offering companies sufficient reasons to already begin using Peppol BIS. 

The decree also addresses rounding for structured e-invoices.  It stipulates that when the VAT amount has more than two decimal places, it should be rounded up or down based on whether the third decimal place is 5 or higher. This rounding is applied to the total VAT amount on the invoice, rather than on individual transaction lines. As a result, companies may need to assess the current processes in their ERP systems, as these systems often calculate and round VAT amounts at individual invoice line level rather than at total level of the invoice.

To ensure adherence to new regulations, the decree outlines penalties for non-compliance (not having the technical means) to issue or receive e-invoices, starting at EUR 1.500 for the first offence, EUR 3.000 for the second, and EUR 5.000 for third and subsequent offences. The fine for the first offence applies to all non-compliant invoices (rather than imposing a fine of EUR 1.500 per non-compliant invoice). The administration will only consider an offence as ‘subsequent’ offence if it occurs at least three months after the previous one, allowing companies sufficient time to meet the necessary requirements. Existing fines for non-compliance remain applicable to e-invoices as well.

Finally, the decree confirms that the provisions enter into force on January 1^st, 2026.

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