What the 2026 B2B mandate and 2028 e‑Reporting plan mean and how to get ready

Royal Decree confirms Belgium’s B2B e‑invoicing mandate

Belgium’s move towards mandatory B2B e‑invoicing is now fully anchored in law.

• A federal law of 6 February 2024 amended the Belgian VAT Code to introduce mandatory B2B e‑invoicing as of 1 January 2026.
• On 8 July 2025, the Ministry of Finance (FPS Finance) issued a Royal Decree on structured e‑invoicing, which was published in the Belgian Official Journal on 14 July 2025. This decree sets out the technical standards for semantics, syntax and transmission, confirms the 2026 start date, and introduces new penalties for non‑compliance.

From 2026, Belgium will rely on Peppol BIS Billing 3.0, fully aligned with the European e‑invoicing standard EN 16931, as the core format for both B2G and B2B e‑invoices. Furthermore, this creates a foundation for near real‑time VAT e‑reporting by 2028 and in alignment with the EU’s VAT in the Digital Age (ViDA) initiative.

Who is affected and what changes on 1 January 2026?

• In scope
  • All Belgian VAT registered businesses including Belgian companies, Belgian permanent establishments of foreign companies and Belgian VAT groups.
  • The obligation applies to almost all domestic B2B VAT‑liable transactions between VAT‑liable entities in Belgium.
• Out of scope
  • B2C transactions are explicitly excluded from the mandate.
  • Certain VAT‑exempt activities under Article 44 of the Belgian VAT Code (e.g. some financial, medical and educational services) sit outside the obligation.
  • Specific exclusions also apply for some foreign taxpayers that are only VAT‑registered in Belgium without a fixed establishment.
• What is the format required of a Peppol e-Invoice?
  • For in‑scope transactions, invoices must be issued as structured electronic invoices, compliant with EN 16931 and typically using Peppol BIS Billing 3.0 (UBL).
  • Sending a simple PDF by email or a paper invoice will no longer be sufficient to meet the legal invoicing requirements for those B2B transactions.

From 1 January 2026, you must be able to send and receive compliant Peppol BIS invoices. If your systems aren’t Peppol‑ready, now is the time to close that gap.

Get ready for e‑Invoicing in Belgium

The Peppol network as the default network

• The Peppol network is the default infrastructure for Belgium
  • Peppol BIS Billing 3.0 over the Peppol network is the recommended transport infrastructure for structured e‑invoicing in Belgium, both B2G and B2B.
  • All businesses in scope must have the capability to send and receive Peppol BIS invoices via the Peppol network, even if they also use alternatives.
• Alternative structured channels are allowed – with conditions
  • Trading partners can mutually agree to use another structured format and/or transmission method (for example, an existing EDI setup), provided:
    • The format can be mapped to EN 16931 semantics and syntax.
    • Neither party is forced to abandon the Peppol track altogether, Peppol connectivity must remain available.
• Hermes as a temporary safety net, but only until 31st of December 2025
  • For entities not yet able to receive structured e‑invoices, Belgium operates the Hermes platform, which converts structured invoices into readable formats such as PDF. Hermes is designed as a temporary inclusion mechanism and will be phased out at the end of 2025.

In short: Peppol is mandatory as a capability, and dominant in practice, but companies with mature EDI integrations can keep using them alongside Peppol, as long as they stay fully compliant with EN 16931.

All businesses in scope must have the capability to send and receive Peppol BIS invoices via the Peppol network

Penalties for not being technically ready

The Royal Decree creates a specific non‑proportional penalty if a taxpayer does not have the technical means to send and receive Peppol BIS e‑invoices via the Peppol network.

The scale is:

• €1,500 – first infringement
• €3,000 – second infringement
• €5,000 – each subsequent infringement

Important nuance: a subsequent infringement is only considered “new” if it is identified at least three months after the previous one, effectively giving businesses a three‑month remediation window after each penalty to bring their systems into compliance.

For companies that are still relying on PDFs or manual processes, this is a strong signal: technical readiness is no longer optional.

Technical readiness is no longer optional and there are penalties for not being ready

Looking ahead: near real‑time e‑Reporting by 2028

e‑Invoicing is only the first phase of Belgium’s digital VAT reform. The 2025–2029 federal coalition agreement and EU documentation confirm the intention to introduce near real‑time electronic VAT reporting on top of e‑invoicing by 2028. Below are a summary of current expectations

• Target date
  • Near real‑time VAT e‑reporting is planned for 1 January 2028, following two years of mandatory B2B e‑invoicing.
• Model: Peppol five‑corner (decentralised CTC)
  • E‑invoicing between businesses will continue to follow a Peppol four‑corner model (supplier → access point → access point → customer).
  • For e‑reporting, the Belgian tax administration is expected to join as a fifth “corner”, receiving invoice data in near real time from Peppol Access Points.
• Impact on compliance
  • The new system is expected to replace the annual VAT client listing (customer listing) over time, shifting from periodic batch reporting to continuous transaction controls.

Belgian tax administration to join as a fifth corner

Mandatory e‑invoicing and near real‑time e‑reporting are key tools to close the VAT compliance gap, combat fraud and modernise VAT administration.

What this means for your business

If you operate in Belgium, whether as a local business, a foreign company with a Belgian fixed establishment, or as part of a VAT group, you should now be working through at least the following:

1. Scope analysis
   • Confirm which entities, VAT numbers and transaction types fall under the B2B e‑invoicing obligation from 2026 and will likely fall under e‑reporting from 2028.
2. Peppol connectivity
   • Ensure every in‑scope entity can send and receive Peppol BIS 3.0 invoices via a certified Peppol Access Point, even if you intend to keep using direct EDI or industry‑specific networks.
3. ERP and billing changes
   • Implement EN 16931‑compliant data models.
   • Update VAT calculation and rounding logic, new rounding rules.
   • Map document flows and exception handling to work with Peppol.
4. Archiving and audit trail
   • Maintain a compliant electronic archive and audit trail for structured invoices (archiving rules themselves do not fundamentally change, but the formats and volumes will).
5. Future‑proofing for e‑reporting
   • Treat e‑Invoicing and e‑Reporting as one continuous programme, not two separate projects; the same data and infrastructure will underpin both.

How to get Peppol-ready fast in Belgium

Arratech provides scalable and secure e-Invoicing infrastructure for Peppol networks. We enable our customers to get their own or shared Peppol certified Access Point and Service Metadata Publisher (SMP), using our modern platform designed for global e‑invoicing and emerging CTC/e‑reporting models.

Arratech provides scalable and secure e-Invoicing infrastructure for Peppol networks.

With Arratech, you can:

• Get full Peppol connectivity via a single unified API
  • Connect your ERP, billing or platform once to Arratech’s Access Point‑as‑a‑Service and SMP as-a-Service, and reach Peppol participants worldwide, including Belgian businesses and public entities.
• Rely on EN 16931 & Peppol BIS 3.0 compliance
  • Our infrastructure are built around the EN 16931 data model and Peppol BIS Billing 3.0, aligning naturally with the Belgian 2026 mandate and the EU’s ViDA framework.
• Prepare for e‑reporting and CTCs
  • Arratech Connect has been designed for CTC and near real‑time reporting, giving you a future proof platform for when Belgium activates its Peppol 5‑corner model in 2028.
• Scale internationally
  • Our platform connects to multiple networks, so your Belgian compliance strategy can fit into a broader global approach instead of a country‑by‑country patchwork.
• Offload operations, security and updates
  • Arratech is ISO 27001, ISO 22301 and Peppol certified, and we handle the behind‑the‑scenes compliance, certificates, monitoring and upgrades, freeing your teams to focus on business processes rather than infrastructure.

Next step: be compliant from day one

Belgium’s 2026 B2B e‑invoicing mandate and 2028 e‑reporting plans are no longer theoretical. The technical rules are published, the fines are defined, and the clock is ticking.

We invite you to talk to Arratech’s Peppol experts about and get advice on the best way for your business to get Peppol-ready

The Belgian mandate is going live soon, but through the Arratech infrastructure and easy onboarding, you can go live fast and be compliant. With the right Peppol infrastructure in place, you can turn compliance into an opportunity to automate, standardise and de‑risk your invoicing worldwide.

GET DEMO