Belgian E-invoicing obligation: What does this mean for international business partners?
Over recent months, we at Peppol.now have been receiving the same question more and more frequently: “What does the Belgian e-invoicing obligation mean for our business?” What’s striking is that this question doesn’t only come from Belgian entrepreneurs themselves, but increasingly — and in growing numbers — from companies in the Netherlands, the United Kingdom, and other countries that do business with Belgian partners.
A Dutch IT supplier delivering software to Belgian companies, a British consultant advising a Belgian group, a German logistics company regularly delivering goods in Belgium — they all face the same question: does the Belgian e-invoicing obligation apply to us too? And if so, what do we need to do?
The Facts at a Glance
From 1 January 2026, Belgium introduces a mandatory structured electronic invoicing requirement for all business-to-business (B2B) transactions between VAT-liable companies. This obligation applies to all Belgian VAT-liable businesses conducting B2B transactions, regardless of their sector or size.
But what does this mean exactly for foreign businesses? This is where it gets interesting, because the legislation makes a clear distinction between different situations.
Scenario 1: The Dutch Supplier Without a Fixed Establishment
Suppose: TechSolutions BV from Amsterdam delivers software to Belgica Industries NV in Brussels. TechSolutions has no fixed establishment in Belgium, but does have a Belgian VAT number for these supplies.
The reality: Foreign businesses that are not established in Belgium are not required to issue structured electronic invoices, even when they are identified in Belgium for VAT purposes. TechSolutions BV therefore does not need to send an e-invoice under Belgian rules.
However: Belgica Industries NV is, from 2026, obliged to receive e-invoices from all its Belgian suppliers. This means it must maintain two different invoicing channels: traditional invoices from foreign suppliers like TechSolutions, and e-invoices from Belgian suppliers.
Scenario 2: The German Company With a Fixed Establishment
LogistikPartner GmbH from Cologne has a branch in Antwerp with its own staff and warehouse facilities. From this Belgian establishment, they provide transport services to Belgian businesses.
The reality: Foreign businesses that have a fixed establishment in Belgium are treated the same as a VAT-liable business established in Belgium and must therefore issue structured electronic invoices. LogistikPartner GmbH is therefore obliged to send e-invoices via the Peppol network.
This is a crucial distinction: it is not the nationality of the company that is decisive, but whether there is a fixed establishment in Belgium.
Scenario 3: The British Consultant Post-Brexit
Advisory Services Ltd from London provides consultancy services to Belgian companies. Since Brexit, the UK is no longer an EU member state, but the company does have a Belgian VAT number for certain assignments.
The reality: The same applies here: no fixed establishment in Belgium means no e-invoicing obligation. Advisory Services Ltd can simply continue invoicing as it always has.
The practical consequence: Their Belgian clients must again maintain two separate invoicing channels.
The Double Administration Problem
This is precisely the core of the problem Belgian companies face. From 1 January 2026, all Belgian VAT-liable businesses must use structured electronic invoices among themselves, but their foreign suppliers (without a fixed establishment) continue to invoice traditionally.
The result? Belgian companies must maintain two parallel systems:
- E-invoices via Peppol for Belgian suppliers
- Traditional invoices (PDF, paper) for foreign suppliers
This means double the work, double the costs, and an increased risk of errors in the administration.
When Does the Obligation Apply?
The obligation for structured electronic invoicing will almost always apply to transactions between a Belgian VAT-liable supplier and a Belgian VAT-liable customer.
For foreign businesses, the obligation applies when:
- They have a fixed establishment in Belgium (own staff, office, warehouse)
- They have a Belgian VAT number and a fixed establishment
Exceptions to the obligation:
- VAT-liable businesses not established in Belgium without a fixed establishment
- Transactions exempt under Article 44 of the VAT Code
- B2C transactions (invoices to private customers)
- Certain flat-rate VAT taxpayers
What Is a Fixed Establishment?
A foreign company will in principle have a fixed establishment in Belgium when it has a place where management tasks are carried out, a branch, factory, workshop, agency, warehouse, office or laboratory. Key criteria are:
- Sufficient permanence of presence
- Appropriate structure in terms of human and technical resources
- Regular supply of goods or services from this establishment
A temporary project or incidental presence does not generally constitute a fixed establishment.
The Peppol Network: The Technical Solution
Structured electronic invoices are sent via a decentralised network called Peppol. Peppol is a standardised network that facilitates secure and efficient exchange of electronic documents between businesses.
For companies that are required to send e-invoices, connecting to the Peppol network via a certified service provider is necessary.
Practical Advice for Belgian Businesses
As a Belgian company, you can avoid the double administration problem by proactively communicating with your international suppliers. Even if they are not required to send e-invoices, it is in everyone’s interest to do so.
The benefits of uniform e-invoicing:
- One invoicing channel instead of two
- Automatic processing of all invoices
- Faster payments through streamlined processes
- Fewer errors through standardised formats
- Better cash flow management
Communicating With International Partners
Explain the following to your foreign suppliers:
“From 2026, as a Belgian company we are required to receive e-invoices from our Belgian suppliers. Although you as a foreign supplier are not obliged to send e-invoices, it would greatly help our collaboration if you were to do so. This prevents us from having to maintain two different invoice processing systems and ensures faster handling of your invoices.”
Immediately offer a path forward: Refer your suppliers directly to practical help. By mentioning websites such as Peppol.now, you not only make a request but also immediately offer a solution. This lowers the threshold and shows that you are thinking along with the practical implementation. Your supplier can find information there about suitable Peppol providers and the steps required for connection.
International Developments
It is important to realise that Belgium is not the only country making e-invoicing mandatory. From 2030, this obligation will also apply to invoicing between EU member states. Companies that invest in Peppol connectivity now are ahead of this European development.
Ensure Clear Communication
For Belgian businesses, our advice is: engage proactively with your international suppliers. Explain why it is beneficial for both parties to switch to e-invoicing, even if they are not required to do so.
For foreign suppliers of Belgian businesses: Seriously consider connecting to the Peppol network. This prevents administrative burden for your Belgian clients and positions you well for the further European digitalisation of invoicing.
Do you have questions about Peppol connection or want to know which service provider best suits your situation?
Visit Peppol.now for more information and check our overview of Peppol providers to find the provider that best meets your needs.
By taking action now, you ensure that your international trade relationships continue to run smoothly after 1 January 2026 — without double administration and with maximum efficiency.
Would you like to stay informed about the latest developments in e-invoicing across Europe? Follow Peppol.now for up-to-date information and practical tips for your business.
