Belgium Formalizes Dual Near Real-Time VAT E-Reporting from 2028: Pre-Draft Law Approved and Annual Client Listing Abolished
KGT Country Update | Belgium | July 23, 2026
At the Council of Ministers of July 18, 2026, on a proposal by Finance Minister Jan Jambon, the Belgian federal cabinet approved a pre-draft law (voorontwerp van wet / avant-projet de loi) amending the VAT Code to introduce mandatory near real-time electronic reporting of invoice data — by both the supplier and the customer — building on the B2B structured e-invoicing mandate in force since January 1, 2026.
The same text abolishes the annual customer listing for taxpayers subject to the new e-reporting obligation. The pre-draft has been sent to the Data Protection Authority and the Council of State for opinion.
Background
Belgium has required structured electronic invoices for domestic B2B transactions via the Peppol four-corner model since January 1, 2026. The 2025–2029 federal coalition agreement announced a second stage — e-reporting of invoice data to the administration from 2028 — but until now that commitment existed only at policy level.
The July 18, 2026, cabinet decision converts it into a formal legislative text, positioning Belgium ahead of the EU ViDA digital reporting requirements due by July 2030.
The Legislative Change
The pre-draft law rests on three pillars:
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Near real-time reporting on top of e-invoicing — certain mandatory invoice data must be reported electronically to the tax administration in near real time, with entry into force planned for January 1, 2028.
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A dual-sided (bilateral) obligation — the reporting must be performed both by the supplier/service provider and by the customer. The government expects this to improve compliance through digitized data flows and to give the administration faster, more detailed, and more reliable information for risk analysis and fraud detection.
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Abolition of the annual client listing — the annual list of taxable customers is abolished for taxpayers subject to the new e-reporting duty, a simplification offsetting the new obligation.
Scope
The obligation attaches to invoice data for transactions within the Belgian e-invoicing framework, on both the sales and the purchase side.
Professional commentary highlights that cross-border and Article 194 reverse-charge flows are expected to enter scope from July 1, 2028, raising concerns about the same data being reported up to three times (supplier e-reporting in its member state, customer e-reporting in Belgium, and the EC Sales Listing under ViDA).
The implementing Royal Decree will define the exact dataset, deadlines, and exceptions.
Timeline
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July 18, 2026 — Council of Ministers approves the pre-draft law; referral to the Data Protection Authority and the Council of State.
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Autumn 2026 (expected) — publication of the law after the advisory opinions and parliamentary passage.
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Early 2027 (expected) — implementing Royal Decree setting the dataset, reporting deadlines, and exceptions.
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January 1, 2028 — planned entry into force of dual near real-time e-reporting; Article 194 flows expected from July 1, 2028.
Businesses Affected
All taxpayers within the Belgian B2B e-invoicing mandate are affected — and, critically, every business becomes a reporter as a customer, not only as a supplier. Large business customers face the heaviest lift: validating and reporting supplier invoice data within a tight window (professional bodies reference an approximately five-day deadline) is not feasible without deep ERP integration on the accounts payable side.
Required Actions
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Plan an accounts-payable-side reporting build in SAP/ERP — the 2026 e-invoicing projects covered mainly the sales side; dual reporting requires inbound invoice data capture, validation, and transmission.
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Strengthen Peppol/EN 16931 data quality controls: near real-time reporting leaves little room for later correction, and poor supplier data becomes your reporting risk.
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Design reconciliation between e-reported data and the periodic VAT return — timing differences, disputed invoices, credit notes, and rebates will generate systematic discrepancies that must be explainable.
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Monitor the DPA and Council of State opinions and the draft Royal Decree for the final dataset, deadlines, and exceptions; budget for a 2027 build window.
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Multinationals should flag the divergence risk: ViDA makes customer-side reporting optional, so Belgium's dual model may require country-specific design.
Practical Implications
The reform delivers one clear simplification — the client listing disappears — but shifts a substantial new burden onto the purchase side. Invoice triage, validation, and dispute cycles routinely exceed five days, so businesses risk penalties for late reporting of data they did not create and may legitimately be contesting.
The business community is pressing for supplier-only reporting while the draft is with the advisory bodies, and views the January 1, 2028, target as ambitious given that final IT specifications will only stabilize with the Royal Decree in early 2027.
Expected Next Steps
After the Data Protection Authority and Council of State opinions, the text proceeds through parliament, with publication expected in autumn 2026 and the implementing Royal Decree in early 2027. Businesses should treat the second half of 2026 as the design window and 2027 as the build-and-test window. KGT will report on the final text, the Royal Decree, and any change to the dual-reporting design.
How Can KGT Support You?
KGT implements Belgian Peppol e-invoicing directly from SAP through our SAP-integrated add-ons and supports SAP Document and Reporting Compliance (DRC) rollouts. For the 2028 e-reporting mandate, we can extend your Belgian architecture to the purchase side — inbound invoice data capture, validation, near real-time transmission, and VAT-return reconciliation — and align the design with ViDA so your investment is reusable for the 2030 EU digital reporting requirements.
Official sources
This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.
