Belgium's forthcoming e-invoicing mandate marks a significant shift in how businesses will conduct financial transactions. This move reflects a broader trend across Europe towards digitalization and modernization of financial processes. However, compared to e-invoicing mandates in other countries, there are a few notable points worth examining.
Big bang implementation
One major difference is that the Belgian government has decided to go for a big bang approach. This means there is no gradual implementation period where all need to be able to receive, and larger enterprises are required to start sending first, followed by the smaller companies at a later stage.
Instead, on January 1, 2026, all invoices exchanged between Belgian VAT-registered entities must be structured electronic invoices. No more PDFs or paper invoices will be allowed! The Belgian federal government foresees several measures to ensure all businesses are properly prepared:
- Informational campaigns by the federal government to inform all businesses about the change and its impact.
- Fiscal measures to support small and medium-sized companies in the IT investments needed to comply with the new regulations, starting January 1, 2025.
- An interim solution, called HERMES, for smaller companies unable to receive e-invoices on January 1, 2026, where the e-invoice is transformed into a PDF invoice.
Interoperability
A second notable element in the Belgian mandate is the explicit requirement for interoperability stipulated in the updated law and the accompanying explanatory memorandum. The success of any e-invoicing mandate depends on clear guidelines regarding content (semantics), format (syntax), and the exchange method. Only when all three factors are clearly defined can stakeholders easily exchange invoices.
The law mandates that the format, syntax, and exchange method for invoices will be determined by law. While this has not been decided yet, there is a strong preference for the Peppol standard. Peppol defines semantics, syntax, and exchange methods, has a clear governance model, and has been the Belgian government’s choice for receiving its own supplier invoices since 2017.
The law also allows for the exchange of other formats and methods, provided both parties agree and the exchange complies with the European norm EN 16931-1 and CEN/TS 16931-2.
Alignment with ViDA
The VAT in the Digital Age (ViDA) proposal, introduced by the EU Commission, aims to modernize the VAT framework to fit the modern business environment while ensuring fairness and efficiency in VAT collection. Although ViDA has not yet been approved and might be subject to further adjustments, Belgium has already aligned its e-invoicing mandate with the Digital Reporting Requirements (DRR), which outline how e-invoices can and should be used to facilitate the exchange of invoice documents, as detailed in ViDA. (More in our blog post on ViDA found here.)
Despite the ongoing approval process for ViDA, Belgium explicitly mentions its alignment with the DRR in the memorandum and has sought approval to implement the mandate as required by current EU regulations.
No e-reporting (yet)
The Belgian e-invoice mandate aims to stimulate the exchange of e-invoices between B2B partners but does not currently include e-reporting requirements. In countries like France, Italy, and Romania, e-invoices are used by local governments to better capture VAT details, helping combat fraud and close the VAT tax gap. These countries impose the exchange of invoice data via a centralized platform or through e-reporting requirements parallel to the invoice flow.
Belgium explicitly states that there are no e-reporting requirements at this point. However, it acknowledges that ViDA will likely require this and indicates that the current framework might lead to e-reporting requirements in the future.
A balanced approach to e-invoicing … with a bang
The upcoming e-invoicing mandate in Belgium represents a progressive step towards modernizing financial processes, enhancing efficiency, and promoting sustainability. While the Belgian mandate may not be as impactful as those in other countries (France, Italy, etc.), it provides concrete measures to ensure clear guidelines for invoice exchange.
The big bang approach, which will require all businesses to switch to e-invoicing on January 1, 2026, may entail some risks, but these can be mitigated with proper preparation.
Want to learn more about the Belgian mandate and how to prepare for it? Contact us today to learn what to expect and how to be proactive.
