Belgium: Peppol Is Live. E-Reporting Is Next
Belgium made structured B2B invoicing compulsory on 1 January 2026, ended its tolerance period in the spring, and has already approved the draft law for the next step: near-real-time reporting of every invoice, by both parties, from 2028. This briefing covers what the first nine months taught, and what 2028 will demand.
Country briefing · Status at 25 September 2026 · CFOs, tax and finance leads
Download Full Briefing (PDF, EN)1 Jan 2026
Structured B2B e-invoicing mandatory, based on the invoice’s issue date
1 Apr 2026
Tolerance ended; full enforcement. Self-billing followed on 1 July
€1,500
First penalty for lacking the means to send or receive, rising to €5,000
2028
Near-real-time e-reporting by supplier and customer, replacing the client listing
Key takeaway for finance and tax leaders: in Belgium the mandate is enforced, and the penalty is framed around capability: failing to have the technical means to issue and receive structured invoices. Because it covers receiving, it reaches customers as well as suppliers. The question this month: do the invoices your suppliers send you reach SAP without manual steps?
The Mandate Is Enforced. The Next One Is Drafted
Since 1 January 2026, invoices between Belgian businesses must be structured electronic documents, exchanged by default over the Peppol network. A PDF is no longer an invoice. The first three months were covered by a tolerance period; since April the rules are enforced, and the government has already approved the draft law that will require both parties to report every invoice to the tax authority from 2028.
The Regime in One Table
| Element | Position |
|---|---|
| Legal basis | The Law of 6 February 2024 amending the VAT Code, and the Royal Decree of 8 July 2025 setting technical rules and penalties |
| Format | Peppol BIS Billing 3.0 in UBL, conforming to the European standard. No Belgian national extension |
| Network | Peppol by default. Another conforming channel only by mutual agreement, and every in-scope business must still be reachable on Peppol |
| No longer a valid invoice. It may travel as an attachment inside the structured invoice | |
| Trigger | The invoice date, not the supply date: anything issued from 1 January 2026 is in scope |
| Next step | E-reporting from 1 January 2028, approved as a pre-draft law in July 2026 |
Key Dates
Structured B2B e-invoicing becomes mandatory
Tolerance ends; penalties apply
Penalties extend to self-billing
Council of Ministers approves the e-reporting pre-draft law
Royal decree with deadlines and penalties expected
Near-real-time e-reporting by supplier and customer
Why the Story Is Not Over
- Sending works for most; receiving often does not. The obligation, and the penalty, covers the ability to receive, which many companies treated as secondary.
- Master data is being tested for the first time. Every counterparty now needs a reachable Peppol identity, and every mismatch is visible.
- 2028 changes the purpose of the data. Today invoices go to the customer. From 2028 their content also goes to the authority, from both sides, where every discrepancy can be matched.
Who It Reaches Inside the Business
| Function | What changed for them in 2026, and what changes in 2028 |
|---|---|
| Billing and AR | Every domestic customer invoiced over Peppol; undeliverable invoices to chase; rounding and credit notes to get right |
| Accounts payable | Supplier invoices arriving as data; the obligation to be able to receive; from 2028, reporting their side too |
| Master data | Peppol identifiers, VAT and enterprise numbers, and addresses, now tested on every invoice |
| Tax | Scope decisions, edge cases, and the reconciliation that e-reporting will make continuous |
A Network, Providers and a Directory
Belgium did not build a government platform. It adopted Peppol, the network already used for public-sector invoicing across Europe, and made it the default route for business invoices. The authority does not sit in the exchange today; from 2028 it will receive a copy of the data.
The Steps, and What Can Go Wrong
| Step | What happens | What can go wrong |
|---|---|---|
| Register | Your business is registered on Peppol through an access-point provider, under its enterprise or VAT number | Registered under one number but addressed under the other |
| Look up | Your system checks that the customer is reachable before sending | The customer is not registered, or registered elsewhere |
| Send | The invoice travels from your provider to the customer’s provider over the network | Content fails validation and is refused |
| Receive | The customer’s provider delivers structured data into their system | It arrives, and nobody processes it |
| Correct | Credit notes correcting structured invoices are themselves structured, over Peppol | Corrections sent as PDF out of habit |
Three Technical Details with Practical Consequences
| Detail | Why it matters |
|---|---|
| VAT rounding | VAT may be rounded only on the total per rate, not line by line. Systems that round per line produce invoices that fail validation or disagree with the customer’s calculation |
| Attachments | A limited set of file types may travel inside the invoice. A customer cannot reject an invoice because no PDF is attached |
| Self-billing | Permitted over Peppol with prior agreement and an acceptance procedure, under its own specification |
Choosing and Holding an Access-Point Provider
- Integration with your ERP, not only a portal
- Transparent validation rules you can apply first
- Status responses returned to the source document
- Readiness for 2028 e-reporting, which will run through providers
- Coverage of your other Peppol countries
- A clean exit, including your registration
Direct Connection or Provider Portal?
Many companies met the January deadline by uploading invoices to a provider’s portal. It works, but it leaves status outside the ERP, invoices re-keyed on the inbound side, and no basis for the reconciliation 2028 will require. A direct system-to-system connection is the durable answer.
The Free Option Has Gone
The government’s free Peppol tool, Hermes, closed at the end of 2025. Every business now needs a commercial provider, which makes the provider a supplier to be managed, not a utility to be assumed.
Domestic, Between Businesses, Established in Belgium
The mandate reaches domestic transactions between businesses established in Belgium. Cross-border and business-to-consumer transactions are outside it, and several edge cases regularly raise questions.
Who Is In and Who Is Out
| Situation | In scope | Notes |
|---|---|---|
| Belgian-established VAT taxpayer to another | Yes | The core of the mandate |
| Foreign company with a Belgian fixed establishment | Yes | For supplies involving that establishment |
| Foreign company with only a Belgian VAT number | No | Proposals to include non-residents from 2028 have been discussed; see section 06 |
| Taxpayers making only exempt supplies | No | Those without deduction rights under the relevant exemption |
| Flat-rate scheme taxpayers | No | The scheme itself ends by 2028 |
| Cross-border B2B | No | Domestic transactions only, for now |
| Business to consumer | No | Unchanged |
Edge Cases that Generate Questions
| Case | Position |
|---|---|
| Credit note for a 2025 PDF invoice | May remain a PDF if the customer agrees; credit notes against structured invoices must be structured |
| Invoice sent to the wrong party | Clarified in the official guidance during 2026; follow the correction procedure rather than re-sending informally |
| Reverse-charge supplies | In scope; the correct tax category codes matter, and were clarified in 2026 guidance updates |
| Small-business franchise scheme | Treatment should be confirmed against the current official guidance |
The Group-Structure Trap
Multinationals often invoice Belgian customers from a foreign entity holding a Belgian VAT number, and assume they are out of scope. If that entity has a fixed establishment in Belgium, they are in, and whether an establishment exists is a question for your adviser, not a default.
How to Confirm Your Own Scope
- List every entity that invoices Belgian businesses, and whether it is established in Belgium or only registered.
- For foreign entities, obtain a view on whether a fixed establishment exists, and document it.
- Identify exempt or special-scheme activity, and whether it is the whole activity or only part.
The Public Sector
Invoices to federal authorities have been structured and routed through the Mercurius platform over Peppol for several years, with the threshold now at a few thousand euros for newer contracts. Flanders and Brussels require it; Wallonia prefers it. For most suppliers, B2G was the rehearsal for the B2B mandate.
The Network Held. Companies Were the Bottleneck
Technically, the rollout went well: no network outages and no central bottlenecks, with Peppol registrations in Belgium passing two million by mid-2026 (a figure inflated by double registrations). The problems were inside companies, and they were predictable.
What Went Wrong
| What went wrong | Why, and what it cost |
|---|---|
| Customers not on Peppol | Invoices could not be delivered. Sending by other means was tolerated in the first quarter; it is not now |
| Master data not fit for purpose | Wrong VAT or enterprise numbers, missing codes, incomplete addresses; each a rejected or undeliverable invoice |
| “Emailing a PDF is e-invoicing” | A persistent belief. A PDF is not an invoice, and the customer cannot deduct VAT on it |
| Receiving treated as secondary | Invoices arrived as data and waited, unprocessed, while AP looked for PDFs |
| Per-line VAT rounding | Totals that disagree between supplier and customer, or fail validation outright |
| Self-billing left late | Its own tolerance ended in June; many schemes were not ready |
What Good Looks Like Nine Months In
- Every customer’s Peppol reachability checked before invoicing
- Undeliverable invoices visible the same day, with an owner
- Rounding per rate total, matching the customer’s calculation
- Inbound invoices matched and posted from data, not re-keyed
- Credit notes flowing the same route as invoices
- Provider statuses returned to the source document
A Remediation Sequence
| Step | What to do |
|---|---|
| 1 · Measure | Count sent, delivered and undeliverable invoices for the last three months, by cause |
| 2 · Clean | Fix the master data behind the undeliverable ones: identifiers, VAT numbers, addresses |
| 3 · Receive | Move inbound from portal download to direct posting in the ERP |
| 4 · Own | Give the daily exception list a named owner in finance, not in IT |
The Belief That Will Not Die
Nine months in, some suppliers still email PDFs to Belgian business customers. Those are not invoices under Belgian law, and the customer who accepts them is taking a deduction risk. Check your own inbound mailboxes; the problem is often visible there first.
The Customer’s Deduction
A customer’s VAT deduction requires a valid invoice, which for in-scope supplies means a structured one. Advisers have described the risk of losing deduction as largely theoretical given European case law, but customers are increasingly unwilling to test that theory, and are refusing PDFs.
The Fine Is for Not Being Able to Take Part
Belgium’s specific penalty is framed around capability: failing to have the technical means to issue and receive structured invoices. Because it covers receiving, it reaches customers as well as suppliers, a feature many companies missed.
The Penalties
| Infringement | Penalty | Applies from |
|---|---|---|
| First | €1,500 | 1 April 2026 |
| Second | €3,000 | If found more than three months after the first |
| Each subsequent | €5,000 | On the same spacing |
| Self-billing arrangements | As above | 1 July 2026 |
These sit alongside the existing penalties for invoicing irregularities, which continue to apply. No published figures on fines actually imposed since April were available at the time of writing.
What the Receiving Obligation Actually Requires
- Registration. Your business must be findable on Peppol under the identifier your suppliers will use.
- A working inbound route. Invoices must arrive somewhere your organisation will see them, ideally directly into the ERP.
- Processing, not just receipt. Technically the obligation is capability; commercially, an invoice received and ignored is an unpaid supplier and a missed deduction.
Where the Exposure Really Sits
The formal exposure: a fixed penalty per infringement, escalating, with existing invoicing penalties on top.
The practical exposure: customers refusing non-compliant invoices and paying late, and suppliers unpaid because their invoices were never processed.
A Quick Self-Assessment
| Question | If the answer is no |
|---|---|
| Are we registered under the identifier suppliers actually use? | Invoices sent to you never arrive |
| Do inbound invoices reach SAP without manual steps? | Receiving works on paper, not in practice |
| Does someone review undelivered and rejected invoices daily? | Receivables stop ageing and nobody notices |
The Number That Matters More Than the Fine
The penalties are modest for a large company. Days sales outstanding is not. An invoice that cannot be delivered, or that a customer rejects, is a receivable that does not start ageing towards payment, and that effect compounds across a billing run.
Every Invoice, Reported by Both Sides
In July 2026 the Council of Ministers approved a pre-draft law introducing near-real-time reporting of invoice data from 1 January 2028. Supplier and customer will both report; the data will flow through the Peppol providers to the authority; and the annual client listing will be replaced.
What Is Known, and How Firm It Is
| Element | What is known | Firmness |
|---|---|---|
| Start date | 1 January 2028 | DRAFT |
| Who reports | Both the supplier and the customer | DRAFT |
| What is reported | Certain mandatory invoice fields, not the full invoice | DRAFT |
| How | A five-corner Peppol model: providers pass data to the authority | EXPECTED |
| What it replaces | The annual client listing | DRAFT |
| Deadlines and penalties | To be set by royal decree, expected in early 2027 | OPEN |
| Non-residents | Inclusion discussed; not confirmed in the approved text | OPEN |
Why Dual Reporting Changes the Game
- Every invoice becomes two records, yours and your customer’s. Any difference between them is visible to the authority automatically.
- Your customer’s data quality becomes your problem. A mismatch caused by their error still produces a question addressed to both of you.
- The ledger has to agree with the network. What you report must match what you post, invoice by invoice, continuously.
What the Authority Will Be Able to See
| Comparison | What a difference suggests |
|---|---|
| Supplier report ↔ customer report | One side has the invoice wrong, or one side has not reported it |
| Reported invoices ↔ VAT return | Tax declared does not match invoicing activity |
| Period over period | Patterns in timing, credit notes or counterparties worth a question |
Open Questions to Watch
- Whether non-resident taxpayers are brought in
- The penalty regime for late or inconsistent reports
- The exact dataset and the reporting deadlines, set by decree
- Whether the customer’s deadline is days after receipt, and how many
What to Do in 2026 for 2028
Most of the work for e-reporting is the work the B2B mandate should already have done: clean master data, reliable statuses, and invoices that match what is posted. Companies that fixed their 2026 gaps are largely ready for 2028; companies that worked around them will meet the same gaps again, this time with the authority watching.
From “Can We Send” to “Can We Prove”
SAP addresses Peppol-based mandates through SAP Document and Reporting Compliance, whose electronic-document framework creates the structured invoice, passes it to the network through a provider or SAP’s own Peppol service, and returns the status to the billing document. The framework exists on both SAP S/4HANA and classic SAP ERP, so Belgium is rarely a platform question.
What “Good” Means in SAP
| Element | What “good” means |
|---|---|
| Reachability | Customer Peppol identifiers held in master data and checked before sending |
| Rounding and content | VAT rounded per rate total; validation applied before transmission |
| Status | Delivery and rejection returned to the document, with a daily view and an owner |
| Inbound | Structured supplier invoices received, matched and posted in SAP |
| Credit notes and self-billing | The same route, the same controls |
| 2028 readiness | A reconciliation between what is sent, received and posted, the basis for e-reporting |
Where Belgian Landscapes Are Usually Weakest
- Portal-based sending, with status invisible in SAP
- Peppol identifiers held outside master data
- Inbound invoices downloaded and re-keyed
- No owner for undeliverable invoices
- Per-line VAT rounding in custom billing logic
- Self-billing handled outside the standard route
Five Questions for Whoever Supports Your System
- How many invoices last month could not be delivered, and who resolved them?
- How are inbound invoices posted: from the data, or by re-keying?
- Does our VAT rounding match the Belgian rule on every invoice type?
- Is our provider preparing for 2028 reporting, and on what terms?
- Can we reconcile sent, received and posted today, invoice by invoice?
SAP’s Peppol Service, or a Third-Party Provider?
| Consideration | SAP’s Peppol service | Third-party provider |
|---|---|---|
| Integration effort | Designed for the SAP framework | Depends on the provider’s connector |
| Other networks and countries | Peppol countries | Often broader, including clearance countries |
| Commercial model | Part of the SAP relationship | A separate supplier to manage |
The Design Decision for 2028
E-reporting will run through the Peppol providers. Whoever carries your invoices will also carry your reporting, so the provider choice made in a hurry for 2026 deserves a second look before 2028.
An SAP Finance and Compliance Practice
Most Belgian work now is not a first implementation. It is closing the gaps a rushed 2026 go-live left, and making sure they are closed before the authority starts comparing both sides of every invoice.
Post-go-live health check
Two to three weeks. Deliverability, rejections, inbound processing, rounding, credit notes and self-billing, evidenced from your system and your provider. Output: a prioritised gap list.
Remediation and 2028 readiness
Master data, inbound automation, status monitoring with an owner, and the sent-received-posted reconciliation e-reporting will depend on. Output: ready for dual reporting.
Run and next country
The e-reporting decree tracked, provider arrangements reviewed, and the same Peppol design extended to your other countries. Output: one network model, many mandates.
What Makes This Different
We are independent of the provider. We help you choose and hold them to account; we do not sell the network.
We treat receiving as half the mandate. Because the penalty does, and because AP is where value is lost.
We design for 2028 now. The reconciliation that e-reporting requires is the same one that proves 2026 is working.
We say what we are not. We are not your tax adviser. We work alongside the people who are.
What a Health Check Produces
Deliverability evidence: invoices sent, delivered and undeliverable by month, with the causes classified.
An inbound position: how supplier invoices actually reach and are posted in SAP, and what is still re-keyed.
A 2028 gap view: where sent, received and posted disagree today, the mismatches e-reporting will expose.
If You Are Ahead
If your deliverability is high, inbound is automated and exceptions have an owner, the remaining 2028 work is modest: a reconciliation and a provider conversation. We will tell you that, and keep the engagement small.
A Sensible First Step
Ask for last month’s numbers: invoices sent, delivered and undeliverable; supplier invoices received as data, and how many were re-keyed. Those four figures show whether 2026 is working, and how much of 2028 is already done.
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Sources consulted 25 September 2026 — FPS Finance and einvoice.belgium.be guidance and FAQs; the Royal Decree of 8 July 2025 as summarised by Loyens & Loeff; Deloitte, BDO, KPMG and EY commentary on enforcement and the 2028 pre-draft law; vatcalc and VATupdate on non-residents and e-reporting; Peppol registration statistics. SAP behaviour from the SAP Help Portal and partner commentary.
Prepared by 30 Advisory (status at 25 September 2026). Information only — not tax, legal or accounting advice. It summarises publicly available material as at that date. The e-reporting law is at draft stage; its implementing decree, deadlines and penalties are not yet adopted; and sources disagree on detail, including the position of non-residents and certain exemptions. Confirm the position for your own entity with the FPS Finance or a qualified adviser before acting. 30 Advisory accepts no liability for decisions taken on the basis of this document.
Is Your 2026 Working, and How Much of 2028 Is Already Done?
We’ll go through last month’s numbers, meaning invoices sent, delivered and undeliverable and supplier invoices received as data, in our free 60-minute diagnostic.
Three things to check first
- Whether invoices sent to you reach SAP without manual steps.
- Whether your VAT is rounded per rate total, not line by line.
- Whether someone reviews undelivered and rejected invoices daily.
Want the full picture? Score your DRC readiness →