E-invoicing: Tolerance of three months announced by the Belgian Federal Public Service Finance

Companies are currently taking the final steps in preparing for the mandatory transition to e-invoicing between Belgian-established and VAT-registered taxpayers as of 1 January 2026. It is expected that this transition will generally proceed smoothly. However, to address practical challenges, the Belgian Federal Public Service Finance (FPS Finance) has announced a three-month tolerance period on 2 December 2025: from 1 January 2026 until the end of March 2026, no penalties will be imposed for breaches of the new e-invoicing obligation, provided that businesses can demonstrate that they have taken ‘timely and reasonable’ preparatory measures.

This tolerance applies, for example, when:

• The business does not yet have the appropriate technical means to send or receive structured e-invoices.
• The company’s own system or that of a third party does not yet allow for the issuance of valid e-invoices.

If the sender or recipient is technically unable to send or receive structured e-invoices during those three months, a regular (paper or non-structured electronic) invoice may be issued temporarily and via another transmission method.

This means that during the three-month tolerance period, PDF invoices (or invoices in any other format) can still be issued and accepted and will still be allowed as a basis for VAT recovery. Additionally, taxpayers involved in self-billing who are unable to process their self-bills because their Peppol Access Point did not implement the Peppol self-billing specification in time, can also continue with PDF self-bill invoices for a limited period.

This is not a general postponement but rather offers taxpayers who have already made sufficient efforts, but did not manage to get ready in time, the opportunity to issue and receive compliant invoices without facing penalties or the risk of rejection of the input VAT. No further guidance is provided on what is considered a ‘timely and reasonable’ effort. The decision to impose penalties will therefore depend on the specific circumstances of each case and will be assessed individually. However, businesses are strongly encouraged to complete the necessary preparations, as the benefits of e-invoicing are significant—not only for companies (including faster payments, reduced administrative costs, fewer errors, enhanced security, and seamless ERP integration), but also for governments (by helping to close the VAT gap and combat fraud). Additionally, taxpayers who are ready for e-invoicing are encouraged to start with e-invoicing despite the tolerance period.

If you have any questions or require support in getting fully prepared, please do not hesitate to contact our KPMG experts, who are ready to assist you.