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As of 1 January 2026, Belgium will implement mandatory structured electronic invoicing (e-invoicing) for B2B transactions. These changes will have a significant impact on your invoicing processes. On 14 July 2025, the Royal Decree was published in the Belgian Official Gazette, laying out the implementation of the Belgian structured e-invoicing obligation.
In our previous Tax Insight (“Mandatory Structured E-Invoicing & Reporting Requirements in Belgium Key Information and Next Steps”), we already provided an overview of the planned reforms. In this update, we delve deeper into the formal confirmations and new elements established in the Royal Decree.
Effective Start Date
1 January 2026
PEPPOL as the Standard – with Nuance
The decree formally establishes that the PEPPOL network, using the PEPPOL BIS format in UBL structure, is the reference framework for sending and receiving electronic invoices. This aligns with the broader European framework regarding semantic and syntactic standards for e-invoicing (EN 16931).
However, a degree of contractual freedom remains: parties may mutually agree on an alternative format and transmission method ("opt-out"), provided the chosen structure complies with European standards. This allows flexibility for industries or supply chains where alternative structures are commonly used.
Mandatory Technical Readiness and Sanctioning Mechanism
Any taxpayer subject to the obligation must have systems capable of sending and receiving PEPPOL BIS invoices. This requirement applies even if the opt-out possibility is used based on mutual agreements.
A new specific, non-proportional penalty is introduced for non-compliance with this technical requirement:
- First identified infringement: €1,500
- Second infringement: €3,000
- Subsequent infringements: €5,000
A period of three months is observed before a new infringement can trigger an additional sanction.
Change in Rounding Practices for Electronic Invoices
A frequently overlooked consequence of the e-invoicing obligation is the change in VAT rounding practices. While VAT is currently calculated and rounded per line item in many systems, the Royal Decree mandates that for e-invoices, this may only be done at the total amount per VAT rate.
This change may require technical adjustments to your ERP or accounting system and impacts reconciliation processes between supplier and customer.
E-Invoicing as a Stepping Stone to Future Digital Reporting
Although the decree focuses solely on e-invoicing, it also anticipates future digital reporting. The expectation that the PEPPOL network will serve as a carrier for near-real-time reporting is hereby implicitly confirmed.
Companies should therefore align their current e-invoicing strategy with this broader, long-term digital transformation within VAT reporting.
Next Steps: What Should You Prioritise Today?
The formal confirmation of the technical modalities leaves little room for delay. Companies that have not yet begun preparations risk operational and fiscal consequences at the turn of the year from 2025 to 2026.
RSM Belgium recommends focusing no later than this autumn on:
- Selecting a suitable PEPPOL Access Point provider
- Reviewing and implementing correct VAT rounding rules
- Raising awareness among internal teams and external partners
RSM Belgium as Your Partner in Digital Compliance
E-invoicing is not just an IT challenge, but a strategic compliance project with tax implications. RSM Belgium has the expertise to support you — from impact analysis to practical implementation
If you would like to receive additional information on this matter or require VAT assistance, the RSM Belgium Tax team is at your disposal [email protected]).
