Belgium Peppol e-reporting: bill before Parliament sets reporting within five calendar days

Brussels, 3 November 2026 – On 27 October 2026 the Belgian government submitted to the Chamber of Representatives the bill introducing electronic reporting of invoice data from 1 January 2028. With that, Belgium Peppol e-reporting takes its legal shape: the law caps the reporting deadline at five calendar days, the data travels through the Peppol network rather than a separate FPS Finance application, and reporting applies in principle on both sides of the transaction. Our article of 20 August 2026 covered the preliminary draft the Council of Ministers approved on 18 July. This article covers what has been fixed since.

What the bill lays down

The bill replaces Article 53quinquies of the Belgian VAT Code. That article contains the obligation to file the annual list of taxable customers, the client listing. For those within the new obligation, it is replaced by electronic reporting per individual supply of goods or services. The periodic VAT return remains; the reporting does not capture everything needed to calculate it, such as transactions with non-taxable persons and adjustments to deductible VAT.

The key points of the text as submitted (DOC 56 1846/001):

• Two-sided. Both the supplier or service provider and the customer report data on the same taxable transaction to the administration.
• Five calendar days at most. The exact deadlines will be set by royal decree, but the law itself caps the reporting period at five calendar days, except in cases of force majeure designated by the King.
• Through Peppol. The law prescribes the Peppol transmission network. According to the explanatory memorandum, FPS Finance will not build a separate application or API.
• No new data. Only information that Belgian VAT rules already require on the structured electronic document can be requested for reporting. The concrete fields will be set by royal decree.
• Discrepancies acknowledged. According to the explanatory memorandum, temporary differences due to invoice date, receipt, disputes or corrections are not errors in themselves. The administration will work with tolerances and a deviation analysis; only significant or persistent differences lead to further verification.
• Scope. Taxable persons not established in Belgium but holding a Belgian VAT number keep filing the client listing for their transactions from 1 January 2028 up to and including 30 June 2030, unless they opt into electronic reporting. Suppliers established in Belgium do report their supplies to such customers. Separate rules apply to VAT groups and the special scheme for farmers. The law enters into force on 1 January 2028.

Why the Data Protection Authority’s opinion matters

On 17 August 2026 the Belgian Data Protection Authority issued opinion 182/2026 on the preliminary draft. It makes clear what the administration intends to do with the data: integrate it into the FPS Finance data warehouse and run automated risk analysis, data mining and network analysis, in particular against carousel fraud. The Authority set conditions. The law must at least contain the maximum reporting deadline. The handling of discrepancies between supplier and customer data must be clearly regulated. A risk signal from automated analysis may not lead to an assessment or penalty without human review. And a fallback mechanism is needed for technical failures at the taxable person, its service provider, the network or FPS Finance.

The Authority also noted that the file did not show whether reporting would run through an FPS Finance application or through Peppol. The bill as submitted answers that question by choosing Peppol, and the explanatory memorandum explicitly refers to the Authority’s opinion for the five-calendar-day maximum. The implementing decree with the data fields, the precise deadlines and the technical arrangements goes back to the Authority for a further opinion.

Belgium Peppol e-reporting in a European perspective

Among its neighbours, Belgium is the first with a domestic near real-time reporting model on the Peppol network. France has run e-reporting through the Plateformes Agréées since 1 September 2026, first for large and mid-sized companies and from 1 September 2027 for the rest. Germany phases in the obligation to issue e-invoices on 1 January 2027 and 1 January 2028 and adds a reporting system from 1 July 2030, with a pilot in 2029. Luxembourg, in bill 8815 submitted on 30 July 2026, opts for mandatory e-invoicing only: receiving from 1 January 2028, issuing in phases from 1 July 2028, with no national e-reporting. The Netherlands, in its policy outline letter of 11 September 2026, is heading for mandatory B2B e-invoicing from 1 July 2030. The ViDA digital reporting requirements apply from 1 July 2030 to intra-EU B2B transactions; according to the explanatory memorandum, the Belgian model is already aligned with those European conditions.

What it means for software vendors and what to do now

For vendors of ERP, accounting and invoicing software, Belgian e-reporting becomes a build order with a fixed start date. The specification of the reporting message only arrives with the implementing decree, but the bill already fixes the architecture. You can design against that.

1. Build two reporting flows. Not only the sales side reports, the purchase side does too. The purchasing module must be able to report a received e-invoice independently of approval or booking. The explanatory memorandum acknowledges that reporting will happen so soon after issue or receipt that the substantive check of the invoice will often not be complete.
2. Prepare the Peppol layer for reporting. The data goes through Peppol. If you run your own access point, extend it; if you work with a Peppol Serviceprovider, ask now for the roadmap for the reporting message to FPS Finance and for support on the purchase side.
3. Count in calendar days. Five calendar days include weekends and public holidays. That calls for queues, automatic resubmission and monitoring of failed reports.
4. Design the correction process. Credit notes, rejected invoices and disputes create different data on each side. Keep the reporting status and the acknowledgement of receipt per invoice so your customer can explain a discrepancy.
5. Make sure the e-invoice itself is complete. Reporting uses only data already on the structured document. Validate VAT numbers, dates and amounts per rate before sending; the administration matches both sides.
6. Make scope configurable. Establishment in Belgium, VAT group membership, the farmers’ scheme and non-established registrations determine whether and how a customer reports. Supplies to a non-established customer with a Belgian VAT number must be reported, while that customer itself keeps the client listing until 30 June 2030. That should be a setting per entity, not custom work.
7. Provide a fallback for outages. The Data Protection Authority asks for arrangements covering failures outside the taxable person’s control. Logging and resubmission are the foundation.
8. Plan on a tight year. The ITAA, the Belgian institute for tax advisers and accountants, expects the law to be published in autumn 2026 and the royal decree in early 2027. That leaves roughly a year between final specifications and 1 January 2028.

For businesses. Any company established in Belgium that invoices a Belgian VAT-registered customer, or buys from such a supplier, will deal with two-sided reporting. Ask your software vendor or Peppol Serviceprovider specifically whether the purchase side is supported, how the five-calendar-day deadline is monitored and how corrections are reported. Phase out the client listing only once the law and the royal decree have been published in the Belgian Official Gazette.

Sources

1. Belgian Chamber of Representatives, bill amending the VAT Code on the introduction of the obligation of electronic reporting and the abolition of the annual list of taxable customers, submitted 27 October 2026 (DOC 56 1846/001), with explanatory memorandum and opinion of the Council of State.
2. Data Protection Authority, opinion no. 182/2026 on the preliminary draft law, 17 August 2026.
3. News.belgium, Introduction of the obligation of electronic reporting of invoice data, Council of Ministers of 18 July 2026.
4. ITAA, E-reporting vanaf 2028: 6 punten om uw kantoor en uw cliënten voor te bereiden, 29 May 2026.
5. Chamber of Deputies Luxembourg, bill no. 8815, deposit, 30 July 2026.
6. KVK (Netherlands Chamber of Commerce), E-facturatie komt eraan, obligation from 1 July 2030.
7. Peppol.now, Belgium e-reporting draft law moves the 2028 obligation forward, 20 August 2026.

Want to know which Peppol Serviceproviders serve the Belgian market and how they are preparing for Belgium Peppol e-reporting from 1 January 2028? Compare providers side by side in the comparison tool for Peppol Serviceproviders and ask specifically about purchase-side support and the five-day deadline.