Belgium’s e-invoicing mandate: first lessons after the deadline
On 1 January 2026, Belgium became the first country in the world to make B2B e-invoicing via the Peppol network mandatory for all VAT-registered businesses. The grace period has now ended. Fines apply. And the first practical experiences are clear enough to draw lessons from, both for Belgian businesses that have not yet fully implemented the requirement, and for international suppliers invoicing Belgian customers.
The figures: a hesitant build-up, then an unprecedented sprint
In early December 2025, approximately 515,000 of the more than 1.2 million VAT-registered businesses required to comply had registered on the Peppol network, just over four in ten, according to an official statement from the Belgian Federal Public Service Finance (FPS Finance). Flemish businesses held a clear lead over Wallonia and Brussels, largely due to earlier B2G obligations and a higher rate of digital maturity.
What followed was an unprecedented final sprint. PeppolCheck.be, the platform that pulls registration data directly from the Peppol register, counted 940,354 registrations on 29 December. Against a total of 1,202,139 VAT-registered enterprises recorded by Statbel for December 2025, that represents approximately 78 per cent. In a single calendar month, more than 425,000 additional businesses had joined.
By mid-March 2026, trade organisation SDZ Federatie reported an adoption rate of 83 per cent based on PeppolCheck.be data, covering 995,819 registered businesses. The regional gap between Flanders and the rest of the country has narrowed significantly since then. Yet approximately 17 per cent of the businesses required to comply remain outside the system, and these are not the businesses with the most margin to ignore that.
Registered is not the same as compliant
One of the most common misconceptions in the first months: ‘we are registered on Peppol, so we are compliant.’ That is not necessarily the case. The law requires both the sending and the receiving of structured invoices. A business that invoices via Peppol but still processes incoming invoices manually as PDFs or by email does not meet the full obligation.
In practice, accounting firms and software providers report that the receiving side is not yet fully operational for a significant share of SMEs. Registering on the network is step one. But automated processing of incoming invoices, without manual intervention, is the step most businesses still need to take. That is precisely the benefit e-invoicing promises: fewer errors, faster processing, lower cost per invoice. Businesses that have only set up the sending side are not yet reaping those benefits.
For businesses looking to strengthen their implementation or considering switching to a different Peppol Service Provider, the comparison tool on Peppol.now offers an independent overview of certified providers, organised by the characteristics that matter for your situation.
What does this mean for international suppliers?
Foreign businesses without a permanent establishment in Belgium are not required to send e-invoices via Peppol, even if they hold a Belgian VAT number. A Dutch IT supplier delivering software to a Belgian customer, for example, has no formal obligation to send a Peppol-compliant invoice.
But the practical reality is more nuanced. Belgian buyers now have to manage two parallel invoice streams: structured Peppol invoices from their Belgian suppliers, processed automatically, and traditional invoices from foreign suppliers, processed manually. For procurement departments with large supplier networks, this creates a measurable difference in processing time and error risk.
The consequence: Belgian buyers are increasingly favouring suppliers who can also invoice via Peppol, even when that is not formally required. International suppliers already certified for Peppol in other markets — such as the Netherlands, Germany or Denmark — can typically extend that capability to Belgium with minimal additional effort. Suppliers who have not yet taken that step can
Fines are now in force: what is at stake?
FPS Finance applied a three-month grace period during the first quarter of 2026: no fines for businesses that could demonstrate they were working toward compliance, provided they continued invoicing through alternative channels. That period ended at the end of March 2026.
The sanctions laid down in the Royal Decree of 8 July 2025 now apply. A first offence carries a fine of 1,500 euros. Repeat offences rise to 5,000 euros, per invoice that is sent or received in non-compliant form. For a business processing a hundred supplier invoices per month, that risk is not theoretical.
What many businesses do not yet know: the receiver can also be fined. A business that is technically unable to receive structured invoices is not compliant with the full obligation, even if it is sending correctly via Peppol.
What has the transition delivered in practice?
Businesses that moved early and properly configured their internal processes report concrete benefits. Invoice processing that previously took two to three days of manual data entry now runs automatically within hours. Payment tracking has become easier because invoice status is digitally traceable. And the number of disputes over missing or incorrect invoice data has fallen, because the Peppol format enforces mandatory fields.
Businesses that have seen fewer benefits are often those that treated the implementation as a technical compliance exercise without adapting their internal processes. They have a Peppol connection, but still process incoming invoices manually. Or they send via Peppol, but their master data (VAT numbers, payment terms, line item codes) is not clean, leading to processing errors on the recipient side.
The lesson is consistent: the choice of a good Peppol Service Provider that also supports you in structuring your invoice process makes a significant difference. Peppol.now offers an independent overview of certified providers, including information on ERP integrations, automated invoice processing and multilingual support.
Which businesses are still behind?
The profile of the 17 per cent that is not yet on the network is consistent. It is predominantly micro-enterprises with low invoice volumes, self-employed professionals in sectors such as rental, construction and the liberal professions, and businesses that have been using the same accounting solution for years, one that was updated late in the cycle.
The barriers are rarely technical. Software vendors had their packages ready in time. The challenge lies on the organisational side: who is responsible internally, have the test procedures been completed, does the accountant know which settings need to be activated? For businesses in this situation, urgency is now high: the grace period is over, and every non-compliant invoice represents a direct financial risk.
2028: the next step is already on the agenda
The e-invoicing obligation is not the endpoint of Belgium’s digital invoicing transformation. From 1 January 2028, Belgium will introduce mandatory e-reporting: invoice data will be transmitted to the tax authority in near-real-time, as an additional obligation on top of the existing e-invoicing requirement. Technically, this builds on the existing Peppol infrastructure, but places additional demands on the completeness and structure of the data exchanged.
Businesses that have built a solid implementation, with clean master data, automated invoice processing and a Peppol Service Provider that actively monitors regulatory changes, will need fewer adjustments in 2028. Businesses that have met the current obligation with minimum effort will face another implementation cycle. The choice made today about the quality of the connection is also a choice about the effort required in 2028.
Frequently asked questions
We are registered on Peppol. Does that mean we are compliant?
Not necessarily. The law requires both sending and receiving structured invoices. Businesses that are registered but still process incoming invoices manually as PDFs or by email do not meet the full obligation. Compliant means your system can both send structured invoices and automatically process them upon receipt.
Do fines apply to small businesses and the self-employed?
Yes. The obligation applies to all Belgian VAT-registered businesses, including the self-employed and small businesses with a VAT exemption based on turnover. Only businesses exclusively performing exempt activities under Article 44 of the Belgian VAT Code fall outside the scope. Fines start at 1,500 euros for a first offence and rise to 5,000 euros for repeat offences, per invoice.
We are a foreign company invoicing Belgian customers. Do we have to use Peppol?
Formally, no. Foreign businesses without a permanent establishment in Belgium are not required to send e-invoices via Peppol, even if they hold a Belgian VAT number. But in practice, if you continue invoicing traditionally while your Belgian customer’s Belgian suppliers deliver automatically, you are creating a manual processing burden for your customer. An increasing number of Belgian buyers prefer suppliers who can also invoice via Peppol, even when that is not formally required.
Our accounting software supports Peppol. Is there anything else we need to do?
That depends. Many packages support Peppol, but the functionality is not always enabled by default. Check that both sending and receiving are active, that your master data is correct (VAT number, payment terms, item codes), and that incoming invoices are automatically read into your administration. Contact your software provider or accountant if you are unsure.
Can we still send a PDF alongside a Peppol invoice?
Yes. You may send a readable PDF as an attachment for convenience. But the legally valid document is the structured invoice sent via Peppol. The PDF has no legal standing as an invoice document in a B2B context between Belgian VAT-registered businesses.
Can we switch Peppol Service Provider if we are not satisfied?
Yes. Your Peppol ID is linked to your company registration number, not to your provider. You can switch without losing your Peppol ID. Allow for notice periods, and ensure the transfer is properly coordinated so that no invoices are lost during the transition.
What changes in 2028 with mandatory e-reporting?
From 1 January 2028, Belgium will introduce mandatory e-reporting: invoice data will be transmitted to the tax authority in near-real-time, as an additional layer on top of the existing e-invoicing obligation. Technically, this builds on the Peppol infrastructure but places additional requirements on the completeness of the data exchanged. Businesses with a solid implementation in place today will need fewer adjustments in 2028.
How do I choose the right Peppol Service Provider for my business?
The right choice depends on your invoice volume, your ERP system, the markets you operate in, and the level of implementation support you need. On Peppol.now you can compare certified Peppol Service Providers independently on these criteria, at no cost.
Sources
Statbel (Belgian statistical office): total VAT-registered enterprises Belgium, December 2025: 1,202,139
FPS Finance / VRT NWS, 4 December 2025: approx. 515,000 registrations at that point, grace period announcement
PeppolCheck.be / ITdaily and DataNews, 29 December 2025: 940,354 registrations
SDZ Federatie / PeppolCheck.be, 16 March 2026: 995,819 registrations, 83% adoption rate
FPS Finance / efactuur.belgium.be: scope of obligation, fine structure (Royal Decree 8 July 2025)
FPS BOSA / bosa.belgium.be: role of the Belgian Peppol Authority
Peppol.now is an independent platform helping organisations find reliable e-invoicing solutions across Europe. Browse certified Peppol Service Providers at peppol.now/comparison.
