- Belgian VAT payers not established in Belgium and without a permanent establishment are exempt from e-invoicing obligations.
- All Belgian VAT-liable companies must use structured electronic invoices between each other starting January 1, 2026.
- Sending a PDF invoice via email or a platform will no longer be sufficient.
- The obligation to use structured electronic invoices applies to transactions between a Belgian VAT-liable supplier and a VAT-liable customer registered in Belgium for VAT purposes, regardless of whether the customer is established in Belgium.
- There are exceptions to the obligation for structured electronic invoices, including:
- Bankrupt VAT payers
- Companies that only carry out transactions exempt under Article 44 of the VAT Code
- Non-resident VAT payers without a permanent establishment
- Flat-rate VAT payers (Article 56 of the VAT Code, expires no later than January 1, 2028)
- There is no obligation to be able to receive structured electronic invoices for:
- Companies that only carry out transactions exempt under Article 44 of the VAT Code
- Non-resident VAT payers without a permanent establishment
- There is no obligation to send or receive structured electronic invoices if the transaction is exempt under Article 44 of the VAT Code.
- The obligation does not apply to outgoing invoices to private customers, but businesses must be able to receive structured electronic invoices from their suppliers.
- Electronic invoicing is mandatory for contracts published after March 1, 2024, for invoicing to public authorities (B2G or business-to-government).
- The obligation generally applies to contracts with a value of 3,000 euros or more (excluding VAT).
- The obligation does not apply if one of the two parties is not VAT-liable.
- To check if a company is VAT-liable, consult the Crossroads Bank for Enterprises (KBO).
- A non-resident VAT payer has a permanent establishment if the conditions described in the VAT commentary are met.
Source: efactuur.belgium.be
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
