Accountancy
05 August 2025

by Nikolas Vandelanotte

Royal Decree confirms: All B2B invoices must be electronic from 1 January 2026

As of 1 January 2026, all invoices between Belgian VAT-liable entities (i.e. B2B invoices) must be issued and sent electronically in a way that allows automatic and electronic processing. This is confirmed by the Royal Decree (RD) of 14 July 2025, which also sets out the technical requirements. Peppol BIS will be the standard format. Read our full overview on e-invoicing via Peppol in Belgium.

In short:

  • From 1 January 2026, every B2B invoice between Belgian VAT-registered businesses must be issued electronically via Peppol

  • The Royal Decree of 14 July 2025 confirms three conditions: structured format, Peppol as the transmission channel, authenticity and integrity

  • A tolerance period of 3 months (until 31 March 2026) applies without penalties

  • Fines for non-compliance: 1,500 euros (first offence) up to 5,000 euros (repeat offences)

  • New rounding rules: VAT amounts are rounded on the total, no longer line by line

What does this mean in practice?

Peppol BIS will be the default format for structured e-invoices. Other formats may still be used if both parties agree and the format complies with European standards. However, every company must be able to send and receive invoices via the Peppol network.

Three conditions for mandatory e-invoicing

The obligation only applies if all the following conditions are met:

  • The invoice is issued by a VAT-registered business established in Belgium that is required to issue an invoice for the transaction. The obligation does not apply to, for example, a mixed VAT taxpayer carrying out exempt transactions.

  • The recipient is also a VAT-registered business established in Belgium. Invoices to private individuals, for example, may still be sent in another format or even on paper.

  • The supply of goods or services takes place in Belgium (with the exception of certain exempt transactions under Article 44 of the VAT Code and intra-Community supplies).

  • What does this mean for your invoice terms?

Read Peppol: what about the opposability of invoice terms and conditions?

Penalties for non-compliance

To “effectively encourage companies to comply with these obligations and, where necessary, sanction them when they do not,” the Royal Decree also introduces administrative fines.

  • €1,500 for a first offence;

  • €3,000 for a second offence;

  • €5,000 for subsequent offences.

There must be at least three months between two findings to give the company time to become compliant. The government has provided a tolerance period until 31 March 2026. During these first three months, no penalties will be imposed, provided that businesses can demonstrate they are in the process of transitioning. From 1 April 2026, enforcement will begin.

In addition, existing fines for not issuing an invoice or for issuing an incomplete or incorrect invoice will also apply to structured e-invoices.

Risk of VAT deduction being denied?

The question arises whether VAT on an incorrect (non-electronically received) invoice will no longer be deductible in the future. The Royal Decree does not provide an explicit answer to this.

However, the general VAT rules state that in order to exercise the right to deduct, the taxable person must have a properly issued invoice containing the mandatory information specified in Article 5, §1 of Royal Decree No. 1.

So yes, theoretically, VAT deduction could be denied. It’s unlikely this will happen immediately, but in the long term, companies may lose their right to deduct VAT if they continue to accept invoices on paper or in non-compliant formats.

New VAT rounding rules

The Royal Decree also changes the VAT rounding rules. For structured electronic invoices, rounding is only allowed on the total VAT amount. Line-by-line rounding will no longer be permitted for these types of invoices from 1 January 2026.

E-invoicing requires preparation

Now is the time to get ready for mandatory e-invoicing. Check whether your current software complies with Peppol standards, and don’t hesitate to contact us if you have any questions.

Are you already invoicing via myVandelanotte? Then you're fully Peppol-proof!

Want to understand step by step how e-invoicing works? Read Mandatory e-invoicing from 2026: what, how & why?

Read our knowledge base article on Peppol for the complete overview.

Frequently Asked Questions

What specifically will the RD change for my business?

The Royal Decree of July 14, 2025 confirms that every B2B invoice between Belgian VAT taxpayers must be issued electronically via the Peppol network as of January 1, 2026. Peppol BIS will be the standard format. Other formats will only be allowed if both parties agree and the format meets European standards.

When does the tolerance period start and what does it entail?

The tolerance period runs from Jan. 1 to March 31, 2026. During this period, no penalties are imposed on companies that are demonstrably in the process of moving to e-invoicing. From April 1, 2026, the penalties do apply.

What are the exact fines for non-compliance?

The administrative fines are: 1,500 euros for a first offense, 3,000 euros for a second offense and 5,000 euros for subsequent offenses. There must be at least three months between two determinations. There is also a risk that VAT deduction on invoices received in error will be denied.

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Nikolas Vandelanotte

Managing Partner | Certified Accountant | Certified Auditor nikolas.vandelanotte@vdl.be

Disclaimer
In our opinions, we rely on current legislation, interpretations and legal doctrine. This does not prevent the administration from disputing them or from changing existing interpretations.


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