Update on e-invoicing in Belgium for the years 2026 and 2028

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In January 2028, Belgium will implement a 5-corner Peppol model, incorporating e-invoicing and near-real-time e-reporting of transaction data.

The newly formed Belgian coalition government announced on 31 January 2025 the confirmation of the 'Federal Coalition Agreement 2025-2029', commonly called the "Arizona deal." This agreement stipulates the implementation of near real-time B2B domestic transaction reporting, known as 'e-reporting', starting from 1 January 2028, utilizing a 5-corner Peppol model. In contrast to the French 5-corner model mandate set for 2026, businesses can either appoint e-invoicing service providers for invoice exchanges or use modified software solutions such as ERP systems, accounting packages, or invoicing systems.

This initiative complements the already established mandate for B2B 4-corner e-invoicing, which is set to take effect in January 2026. The requirements will apply to VAT-registered businesses, including non-residents with a VAT Fixed Establishment (FE) in Belgium. However, non-residents lacking a Belgian FE will only be required to receive Peppol or other EN16931 standard structured e-invoices from their Belgian business partners.

Furthermore, the agreement includes an extension of the Belgian fiscal cash register mandate specifically for the hospitality sector.

The 2026 Belgian mandate is primarily founded on the Peppol 4-corner model, which does not require direct government reporting. However, other exchange platforms may be utilized through mutual agreement, provided they comply with EU regulations. Suppliers and buyers can engage in this process via e-invoicing Service Providers or e-invoice-enabled software and billing systems. To date, Belgium has not announced a formal accreditation system for providers, unlike the system in place in countries such as France.

On 15 October, the Belgian Federal Public Service Finance (FPS) released a list of registered accounting software for e-invoicing, which will become mandatory for resident businesses starting 1 January 2026. This software facilitates the necessary exchange of Peppol-based structured B2B e-invoices among resident companies.

In January 2028, Belgium plans to transition to a 5-corner Peppol model. In addition to e-invoicing, this model will incorporate near-real-time e-reporting of transaction data based on e-invoices, replacing the annual customer listing report. This initiative aims to mitigate the VAT Gap, which is the disparity between projected and actual tax revenue. The EU's most recent estimate of the Belgian VAT Gap stands at €4.8 billion annually.

The FPS has provided guidance to all taxpayers regarding the e-invoicing mandate set to take effect in 2026.

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