Belgian VAT e-invoicing & e-reporting: are you prepared?

1. “B2G” e-invoicing

As from April 2023, e-invoicing will be obliged in Belgium for public contracts and concessions (B2G - Business to Governance) with a minimum estimated value of €30.000, and only €3.000 as from October 2023.
Until now, the threshold amounted to €215.000 . As the threshold will decrease in the coming period a signifcant increase of transactions falling under the scope of the mandatory e-invoicing obligations will occur.

2. “B2B” e-invoicing

For invoices between taxable persons (“B2B”) the implementation of mandatory e-invoicing is likely to take place in three phases:

  • July 2024: mandatory e-invoicing for large taxable persons;
  • January 2025: mandatory e-invoicing for medium-sized taxable persons;
  • July 2025: mandatory e-invoicing for small taxable persons.

According to the EU proposal ‘VAT in the digital Age’, digital reporting obligations will soon be implemented for VAT taxable persons to periodically or continuously submit data in a digital way on all (or most of) their transactions, including by means of mandatory e-invoicing.
E-invoicing will be the default system, taxable persons will always be allowed to issue electronic invoices according to the European standard and will no longer require authorization of the recipient. Some specific data will have to be included in the required content of the invoices.

3. E-reporting as from 2028?

For cross-border B2B transactions, the European Sales Listing will be replaced with a digital reporting requirements system for intra-Community transactions. Within two working days, each invoice has to be transmitted to the tax authorities.
In addition, this system can also be extended to local supplies.

Although there are still a lot of uncertainties about the practicalities, one thing is sure: e-reporting will be implemented in all EU Member States over the next years.

4. Impact

It is clear that, once e-reporting is implemented, the risk of fines and interest will increase significantly, as any errors will be detected automically and immediately by the Belgian tax authorities.
Even if there is still some uncertainty regarding the exact timing and full scope, we highly recommend to prepare yourself for this ongoing digital revolution and to take the necessary actions, starting with a solid VAT basis.

Are you fully confident that your current flows (both incoming and outgoing) are entirely VAT compliant/ correct? If you have any doubts, RSM offers you a VAT quick scan, helping you detect the areas at risk.


If you would like to receive additional information on this matter or VAT assistance of any kind, the tax team of RSM Belgium is at your disposal.