Belgium: Three-month tolerance period for e-invoicing mandate effective January 1, 2026
Tax authority will not impose penalties for infractions related to new e-invoicing obligation during first three months of 2026.
The Belgian tax authority (Service Public Fédéral Finances, SPF Finances) on December 2, 2025, announced a three-month tolerance period for the new electronic invoicing (e-invoicing) mandate between Belgian businesses subject to value added tax (VAT), effective January 1, 2026.
Background
Belgium introduced mandatory e-invoicing for business-to-business (B2B) transactions between Belgian taxpayers subject to VAT, starting January 1, 2026. Over half a million businesses have already adopted e-invoicing, with accelerated onboarding observed since September 2025. The transition is expected to be straightforward for most companies, though some are still finalizing preparations.
Tolerance provisions
The tax authority will not impose penalties for infractions related to the new e-invoicing obligation during the first three months of 2026. This tolerance applies only if the taxpayer can demonstrate that reasonable and timely efforts were made to comply with the mandate. Covered infractions include:
- Not yet having the technical means to send or receive structured e-invoices (fully or for certain transactions, such as self-billing).
- Failing to issue structured e-invoices due to system limitations, either internally or with third-party providers (fully or for certain transactions, such as self-billing).
Taxpayers must continue to fulfill their invoicing obligations using alternative formats or transmission methods if unable to comply with the structured e-invoicing requirement.
Conditions for tolerance
Tolerance is conditional on the taxpayer having taken reasonable and timely steps to comply. Each case will be assessed individually, and sanctions may apply if insufficient efforts are demonstrated. The tax authority clarified that there will be no general extension of the mandate, in order to maintain fairness and avoid delaying the benefits of e-invoicing.
Next steps
Taxpayers need to actively prepare for compliance and document their efforts. The tax authority will evaluate individual circumstances in cases of non-compliance during the tolerance period.
For more information, contact a KPMG tax professional:
Philippe Stephanny | philippestephanny@kpmg.com
Ramon Frias | ramonfrias@kpmg.com