Executive Summary:
Belgium is implementing mandatory B2B e-invoicing, slated to take effect on 1 January 2026. This initiative aims to combat tax evasion and aligns with the EU’s broader “VAT in the Digital Age” (ViDA) proposal. The Peppol framework is the preferred standard, though alternatives are permitted with mutual agreement, as long as they comply with the European Norm. The government offers a temporary solution called “Hermes” for receiving e-invoices, but businesses are encouraged to adopt comprehensive solutions. Tax incentives are available to support the transition. Near real-time data transmission of VAT transactions is planned for 2028.
Key Themes and Details:
- Mandatory B2B E-Invoicing Implementation:
- Effective Date: 1 January 2026. “Mandatory B2B e-invoicing in Belgium is scheduled to come into effect on 1 January 2026.” There is no gradual roll-out.
- Scope: Most VAT-registered taxpayers in Belgium are affected. Exemptions include those under the special flat rate regime, bankrupt taxpayers, and those exclusively carrying out VAT-exempt transactions. Taxable persons registered for Belgian VAT but who are not established in Belgium must also be able to receive structured e-invoices from their Belgian suppliers.
- Legislative Progress: The Belgian Parliament has approved the draft bill, amending the Value-Added Tax Code and Income Tax Code of 1992.
- Technical Framework and Standards:
- Preferred Standard: Peppol. “The Belgian government plans to use the Peppol framework as the default standard for B2B e-invoicing, as it is already used for B2G transactions.”
- Alternative Frameworks: Permitted with mutual agreement, provided they comply with the European Norm. “However, upon mutual agreement, parties can agree on other frameworks or standards, provided they comply with the European Norm.”
- Hermes Solution: A temporary, basic solution provided by the government for receiving Peppol BIS invoices and converting them to PDFs, delivered via email. “Hermes is a basic solution that can receive Peppol BIS invoices over the Peppol Network and convert these into PDFs, which are then distributed to the business via e-mail. However, Hermes is considered a temporary measure and will be discontinued within a few years.”
- Alignment with EU’s ViDA Proposal:
- Belgium intends to align its e-invoicing obligations with those in the ViDA proposal. “Yes, Belgium intends to align its e-invoicing obligations and requirements with those expressed in the ViDA proposal.”
- 5-Corner Model: The government is likely moving toward a “5-corner model,” which aligns with the ViDA proposal. “The government is likely clarifying its commitment to evolving the expected B2B e-invoicing requirements into a 5-corner model, firmly aligning with the ViDA proposal.” The specific details of the 5-corner model are not detailed in the provided sources.
- Tax Incentives:
- A 20% increase in the investment deduction for digital investments from 1 January 2025. “From 1 January 2025, a 20% increase in the investment deduction for digital investments.”
- SMEs and entrepreneurs using subscriptions may apply cost deductions of 120% for invoicing-related technology and packages in taxable periods from 2024 to 2027. “In taxable periods from 2024 to 2027, SMEs and entrepreneurs using subscriptions may apply cost deductions of 120% for invoicing-related technology and packages.”
- Near Real-Time Data Transmission:
- Planned implementation of near real-time transaction reporting requirements by 2028. “The Belgian Federal Government intends to implement near real-time transaction reporting requirements by 2028.”
- Involves automatic data transmission to Belgium’s tax authority.
- Likely integration of cash registers, payment systems, and invoicing systems. “This will involve automatic data transmission to Belgium’s tax authority and will likely integrate cash registers and payment and invoicing systems.”
- Specifics are still under development.
Timeline of Developments (from Pagero Source):
- 2026-01-01: Mandatory B2B e-invoicing comes into force.
- 2028: Near real-time data transmission requirements are intended to be implemented.
- 2025-01-01: 20% increase in investment deduction for digital investments.
- 2024-2027: 120% cost deductions for SMEs and entrepreneurs using subscriptions for invoicing technology.
Implications:
- Businesses operating in Belgium need to prepare for mandatory e-invoicing by 1 January 2026.
- Adoption of the Peppol framework or other EN-compliant solutions is crucial.
- Businesses should consider long-term e-invoicing solutions rather than relying on the temporary “Hermes” solution.
- Monitoring updates from the Belgian government regarding specific requirements for near real-time data transmission is important.
- Businesses may be able to benefit from available tax incentives to offset the costs of implementation.
