Belgium: Guidance addressing structured e-invoicing

FPS Finance on July 8, 2025, issued a Royal Decree concerning the implementation of structured electronic invoicing (e-invoicing) in Belgium. The decree focuses on practical aspects, establishing technical standards for interoperability and efficiency.

Starting January 1, 2026, e-invoicing will be mandatory for all business-to-business (B2B) transactions in Belgium. This applies to taxpayers established and value added tax (VAT) registered in Belgium, foreign companies with a fixed establishment in Belgium, and VAT groups, excluding certain VAT-exempt services under Article 44 of the VAT Code.

Main provisions of the Royal Decree address:

• Interoperability: The decree addresses interoperability challenges by setting standards for semantics, syntax, and technical interoperability, mandating the use of Peppol BIS through the Peppol transmission network. While flexibility is allowed to use other formats, compliance with EU norms is required, and companies need to maintain the capability to use Peppol BIS.
• Rounding: The decree stipulates that VAT amounts with more than two decimal places need to be rounded based on the third decimal place. This rounding applies to the total VAT amount on the invoice, necessitating potential adjustments in ERP systems.
• Compliance: The decree outlines penalties for non-compliance, starting at €1,500 for the first offense, €3,000 for the second, and €5,000 for subsequent offenses. The administration considers an offense as “subsequent” only if it occurs at least three months after the previous one.
• Timeline: The decree's provisions will take effect on January 1, 2026.

Read a July 2025 report prepared by the KPMG member firm in Belgium