E-Invoicing in Belgium

by | Jul 17, 2024 | E-invoicing

Updated on July 17, 2024

Belgium was planning to implement a PEPPOL-based e-invoicing system in July 2024. Unfortunately, these plans got postponed. Read more about the latest updates in our blog.

Overview

As of 2022, the Flemish government has reached their e-invoicing goals. This means that government entities are required to utilize e-invoicing under the European Directive 2014/55/EU. Since 2017, the Flemish government has required e-invoices from all of its suppliers.

B2G E-Invoicing

Business-to-government e-invoicing is mandatory since March 1, 2024, except for contracts under the threshold of 3,000 euros (subject to exception). All public authorities must be able to receive e-invoices and select public authority suppliers are required to send their invoices in the specified electronic format (PEPPOL BIS).

End-to-End E-Procurement

Vlaanderen, the official gateway for the Flemish government, indicated that the Flemish government’s approach is a commitment to fully digital processing of public procurement and related processes: end-to-end e-procurement. Since 2015, the Flemish government has ruled that all businesses must be able to receive e-invoices.

The Introduction of B2B E-Invoicing in Belgium

Belgium was planning to implement a PEPPOL-based e-invoicing system in July 2024. The proposed e-invoicing reforms were designed to increase tax revenues with the initiative to reduce the VAT gap.

Unfortunately, these plans got postponed. Opposition parties in the Belgian parliament have rejected the proposal, questioning the government’s revenue projections associated with the plan. Political consensus-building and reform review efforts will have to wait until after the 2024 summer elections. Due to this postponement, it has been decided that e-invoicing reforms in Belgium will be implemented from January 2026.

Finance Minister Vincent Van Peteghem has reached an agreement in the Council of Ministers on the mandatory introduction of digital invoicing (e-invoicing) between businesses starting from January 1, 2026. While this requirement already applies to invoices provided to the government, Minister Van Peteghem ensures that as of January 1, 2026, structured electronic invoices will also become the standard for transactions between taxable companies.

In July 2024, the Belgian Federal Public Service Finance has published new guidelines for the transition to B2B e-invoicing. According to it, the obligation for structured electronic invoicing will almost always apply to transactions between two Belgian companies subject to VAT.

There is no obligation to send structured electronic invoices for:

  • Bankrupt VAT taxpayers
  • Companies only carrying out transactions exempted by Article 44 of the VAT Code
  • VAT payers not established in Belgium without a permanent establishment
  • Flat-rate VAT payers (Article 56 of the VAT Code, extinct by January 1, 2028 at the latest)

There is no obligation to be able to receive structured electronic invoices for:

  • Companies carrying out only transactions exempted by Article 44 of the VAT Code
  • There is no obligation to send or receive structured electronic invoices if the transaction is exempted by Article 44 of the VAT Code.

The government has opted to utilize the European PEPPOL network for this new development. When a company joins this network, it automatically connects with all other participants in this network. This network is already in use in many other EU member states.

Aleksandra Vovchenko
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