Get ready for the mandatory e-invoicing transition

As of 1st January 2026, the law will mandate electronic invoicing (e-invoicing) via the Peppol network. This signals the end of Word, Excel, PDF, or paper invoices. While 2026 might seem distant, it's crucial to take the necessary steps now to prepare and avoid any nasty surprises. In this article, you'll find out exactly what this change entails and how you can get your business ready for the transition.

Electronic invoicing, also known as e-invoicing or digital invoicing, is growing in importance globally. Large companies have been using it for years, and since 1st March 2024, it has also been mandatory for companies dealing with the government (‘B2G’ or ‘business-to-government’) for contracts exceeding €3,000 excluding VAT.

The Belgian government is rolling out e-invoicing in phases, and by 2026, it will be mandatory for all B2B transactions.

However, let’s start at the very beginning...

What exactly is an E-invoice?

Under VAT legislation, two types of electronic invoices are considered to hold the same legal value as a paper invoice:

• the ’standard‘ electronic invoice. This includes invoices in formats like Excel, Word, or PDF. Their structure and layout are flexible, provided all the required details are included.
• the structured electronic invoice, which can be handled completely and fully automatically by computer systems, accounting software and other business applications. This type of invoice will be mandatory as from 2026.

Why should you switch to E-invoicing?

E-invoicing is safer, faster, and more reliable. It reduces the risk of errors and significantly lowers processing costs.

Studies suggest that businesses can save up to €9 per invoice. The government estimates that companies and authorities combined could save a total of €1.8 billion annually in administration costs (Source: Unizo).

Timeline for the roll-out

• 2024 was the year in which companies were encouraged to take the step voluntarily.
• The year 2025 has been designated as the intensive preparation phase, in which enterprises must take specific steps towards implementation. This phased approach gives everybody sufficient time to adjust to the new reality. Invoices in excel/word/pdf remain legally valid in all situations until 31 December 2025, provided there is explicit or tacit acceptance by the invoice recipient.
• As from 1 January 2026, this condition expires and both the delivery and receipt of an electronic invoice will become mandatory for B2B transactions.
• As from 2030, this duty will also apply to invoicing between European member states.

Are there exceptions to this rule?

• Very little will change for those running a shop, café or small retail business whose activities are focused on selling to private individuals. Indeed, the obligation to use e-invoicing does not apply to B2C sales. 
  Please note: these businesses must, however, be able to receive incoming e-invoices from their suppliers, since these are B2B transactions! Therefore, you will still need to adapt your systems by January 2026!
• Micro-enterprises with an annual turnover of less than €25,000 and a limited number of invoices may potentially be exempt from the obligation (article 44 in the VAT Code).
• Is one of the two parties exempt from VAT? Then the obligation does not apply for their mutual transactions. Check the Crossroads Bank for Enterprises (section Characteristics) to find out if the other party is exempt from VAT.

Specific rules apply in the case of international trade.

Peppol: one standard, one network

In order to offer companies a uniform solution, Peppol has been introduced by the European Commission and a consortium of member states. Peppol stands for “Pan-European Public Procurement On-Line” and is an international, standardised and securely protected network for the purpose of exchanging invoices and other business documents between different systems and organisations.

Every company that is required to start e-invoicing must begin by registering on Peppol. By registering, you confirm your agreement to receive and send structured electronic invoices. Once you have joined the Peppol network, you can also receive and send invoices to companies outside Belgium who are affiliated with this network.

Access to the network is gained through certified service providers (access points). This can be compared to a telecom network. By making Peppol mandatory for the entire B2B sector, the government hopes to combat phishing, data theft and VAT fraud, which are much more prevalent in e-mail traffic. Peppol will also continue its evolution, because within the next ten years it is anticipated that all electronic invoices will be transferred directly to the tax department.

More than 70% of the large companies in Belgium are already affiliated with Peppol, and the current adoption level among SMEs is 35%. Even so, studies show that many companies are still insufficiently informed of the new legislation.

Transition period

In order to support companies during the transition period, governments are offering a free system in which traditional invoices can be entered and converted manually into e-invoices.  However, this is only an emergency solution for sporadic use during the transition period:

• Mercurius which can be found on: Mercurius (belgium.be) – only for invoices from Belgian companies to the different governments
• Hermes which can be found on: Hermes (hermes-belgium.be) – B2B only

Companies can use Mercurius themselves and completely free of charge. Hermes is used through your service provider.

It is better to take a systematic approach and to immediately contact your accountant or the provider of your accounting software (see below).

How do you implement e-invoicing?

To get started with e-invoicing, some good preparation is required. In any case, you will always need the recipient's CBE number. In addition, the format and structure of the e-invoice are standard, so you cannot change anything. In fact, without the required details, you are simply unable to generate an e-invoice.

Start your preparations in plenty of time, because in some cases you will also require new software!

A summary of focus points:

Do you use an ERP system?

• Check whether your ERP system is suitable for e-invoicing and still meets the requirements of your enterprise.
• Find a certified Peppol Access Point. This is a service provider (comparable with a network provider) who takes care of the connection between your ERP system and the Peppol network.

Please note

• Are you active in Belgium? It is best to choose a Belgian service provider. They will be familiar with the local legislation and VAT regulations and offer solutions to suit the Belgian context.
• Internationally active? Choose a service provider with strong international cover who meets the e-invoicing regulations in the countries where you operate and who complies with both local and international legislation.
• Bear in mind that some ERP systems and invoicing packages already have an integrated Peppol Access Point, while others do not. Always take these points into consideration when making your decision.

Do you use an invoicing package?

Check whether your current accounting package supports e-invoicing. If the package does support it, you can follow the steps provided by the supplier to switch over to e-invoicing. If not, consider switching to a different invoicing package.

Not using a digital solution yet?

Do you still generate your invoices in Word or Excel? In recent years, many solutions have been launched that focus in particular on companies with small invoice volumes. Start by making an analysis of your requirements: do you also want to include other processes, besides the invoicing process? For example, the quotation process, booking proposals, payment or sending reminders. The result of this exercise will determine which application is suitable for you.

Get in touch with your accounting office and ask about the extent to which you can use their accounting software for e-invoicing and which functionalities this offers. When doing so, it is important to check that the application is able to both receive and send invoices.

Support measures

The Belgian government has compiled an extensive support package to ease the transition to e-invoicing.

At the federal level, there are two supporting preferential measures available to SMEs and the self-employed:

• As from 1 January 2025, the investment deduction for digital investments increases to 20%.
• The Belgian government offers a tax benefit for companies switching to e-invoicing, with which you can deduct 120% of the costs for implementation and usage between 2024 and 2027 from your taxable profit. This covers costs for software procurement, staff training and consultancy, along with recurring usage costs, such as the cost of your subscription. In this case, the supplement that you are paying because of e-invoicing must be mentioned separately on the invoice.
• Enterprises in Brussels can also make use of the digitalisation bonus from Brussels Economy and Employment. This bonus covers, for example, digitalisation of internal business processes, which includes e-invoicing.

Tip: VAT and cost deduction

As from 1 January 2026, as a self-employed professional, you will only be able to deduct VAT based on structured electronic invoices that meet all legal requirements (Article 5, § 1, of the Royal Decree no. 1 of 29.12.1992).

Costs on private invoices, such as energy and water bills, can, however, still be entered based on paper and non-structured electronic invoices. After all, these invoices are not affected by the new legislation of issuing and receiving structured electronic invoices.

Possible sanctions

Should you refuse to use structured electronic invoices in your B2B activities as from 1 January 2026, then the tax department will consider that no invoice has been issued, which can lead to a fine. Furthermore, the invoice recipient will not be able to recover the VAT that has been paid. In fact, only the VAT on a ‘compliant’ invoice (i.e. an invoice that meets all legal requirements in terms of format and content) will be deductible. In other words, in the future, if you and your customers wish to continue claiming back the VAT that you have paid, you have no choice but to switch to electronic invoicing.

Want to find out more?

• The FPS Finance dedicates specific pages on its website to e-invoicing. For general questions you can send an e-mail to e-invoicing@minfin.fed.be
• The FPS Finance, FPS Economy and FPS Policy and Support have developed a specific portal about e-invoicing: https://einvoice.belgium.be/. There, among other things, you will find a specific explanation about the approach, plus a list of compliant software solutions
• Inter-sectoral and sectoral enterprise organisations such as UNIZO, VBO and Agoria offer their members specific support through seminars, advice, tools, templates, etc.