Belgium e-reporting draft law moves the 2028 obligation forward

Brussels, 20 August 2026 – On 18 July 2026, on a proposal by Minister of Finance Jan Jambon, the Belgian Council of Ministers approved a preliminary draft law amending the VAT Code. The text introduces an obligation to report invoice data electronically and repeals the annual list of taxable customers. With that decision, the Belgium e-reporting draft law turns a commitment in the coalition agreement into a concrete legislative text, now submitted for opinion to the Data Protection Authority and the Council of State.

We described how the Belgian model works in our earlier report on near real-time e-reporting through the 5-corner Peppol model. This news item covers the procedural step taken since then, and what that step does and does not settle.

What the Council of Ministers approved

The official cabinet communication is brief but explicit. Since 1 January 2026, Belgian taxable persons must issue structured e-invoices for domestic business-to-business transactions. Building on that obligation, the preliminary draft introduces near real-time electronic reporting of certain mandatory invoice data to the tax administration. Three elements stand out:

• Dual-sided reporting. The obligation applies to the supplier or service provider and to their counterparty. Not only the sales side reports, the purchase side does too.
• Repeal of the annual customer listing. The annual list of taxable customers can be abolished for those taxable persons who fall under the new reporting duty.
• Stated objectives. The government gives two reasons: better taxpayer compliance through digitisation of the data flow, and faster, more reliable information for risk analysis, fraud detection and audit work.

The preliminary draft has been sent for advice to the Data Protection Authority and the Council of State. Only after those opinions will the text move on to Parliament.

Why this step matters

Until July 2026, the Belgian e-reporting ambition existed mainly as a policy line in the 2025-2029 federal coalition agreement and in communication from FPS Finance. There was no text that lawyers, software vendors or accountants could build on. Now there is one, in preliminary draft form.

Technically the reform builds on infrastructure that is already running. The 4-corner Peppol model has been live in Belgium since January 2026; the 5-corner model, in which the tax administration joins as the fifth corner, is the 2028 ambition. Governance is moving with it: the transfer of the Belgian Peppol authority role to FPS Finance follows logically once the network takes on a fiscal function. Belgian traffic has also grown sharply since the mandate took effect, as set out in our analysis of Peppol network growth in 2026.

What the Belgium e-reporting draft law settles and what it leaves open

The direction is clear; the detail is not. Based on the official communication, the following appears reasonably settled: the dual-sided design, the repeal of the annual customer listing for taxable persons in scope, and the link to the existing e-invoicing obligation.

What remains open is substantial:

• The exact dataset. Which mandatory invoice fields must be reported is not set out in the preliminary draft but will be fixed by Royal Decree.
• Reporting deadlines and exemptions. These also belong to the implementing decree.
• The opinions of the Data Protection Authority and the Council of State. Both bodies can prompt amendments, particularly on data protection in a continuous transaction data flow.
• Parliamentary treatment. A preliminary draft law is not a law. Until publication in the Belgian Official Gazette, the text can change, and in principle so can the date.

Professional bodies, including the Belgian institute ITAA, work on the assumption that the law will be published in autumn 2026 and that a Royal Decree with the implementing rules will follow in early 2027. That timeline is an expectation, not a confirmed official schedule. Taken as a working hypothesis, it exposes the pressure point immediately: roughly one year would remain between final specifications and the 1 January 2028 start date.

What this means for Dutch and Belgian organisations

For taxable persons established in Belgium, the most significant change is that the purchase side acquires a reporting role. Under the 2026 mandate the weight sat on the sales side and on the ability to receive e-invoices. A dual-sided system reaches accounts payable, invoice approval workflows and the reconciliation with the periodic VAT return. That is an ERP question, not a settings question.

For Dutch organisations with a Belgian establishment, subsidiary or VAT registration, the obligation is in the first instance aimed at taxable persons established in Belgium. Companies trading in Belgium without an establishment should follow the scope provisions in the final text closely, because that is where movement is still possible.

For accountants and bookkeeping firms, the medium-term gain lies in losing the annual customer listing. That obligation only disappears for taxable persons actually subject to the e-reporting duty, and only once the law and the implementing decree are in place. Phasing out the listing process earlier would be premature.

Seen from Europe, Belgium is running ahead. The ViDA Digital Reporting Requirements apply from 1 July 2030 to intra-EU business-to-business transactions. Belgium starts two and a half years earlier, and for domestic transactions as well. For multinationals that creates a window in which a national design is needed alongside a later European one.

How to prepare now for the 2028 obligation

There is useful work to do before the implementing rules are known. Check the quality and completeness of your invoice data, because near real-time reporting leaves little room for later correction. Map the channels through which purchase invoices arrive and how long your approval cycle takes. Discuss the 2028 roadmap with your Peppol Serviceprovider and ask specifically about 5-corner support and about the purchase side. Watch the opinions from the Council of State and the Data Protection Authority, since those will show how sharp the final text becomes. To assess whether your current supplier is ready for what the Belgium e-reporting draft law sets in motion, use the Peppol Serviceprovider comparison tool to compare providers on their support for the Belgian market.

Sources

1. News.belgium, Invoering van de verplichting tot elektronische rapportering factuurgegevens, 18 July 2026.
2. News.belgium, Instauration de l’obligation de rapportage électronique des données de facturation, 18 July 2026.
3. KPMG TaxNewsFlash, Belgium: Proposal to introduce e-reporting of invoicing data from 2028, 22 July 2026.
4. VATupdate, Ahead of ViDA: Belgium Formalises Dual Near Real-Time VAT E-Reporting from 2028, 22 July 2026.
5. ITAA, E-reporting vanaf 2028: 6 punten om uw kantoor en uw cliënten voor te bereiden, 29 May 2026.
6. Peppol.nu, Belgium E-Reporting 2028: Near Real-Time via 5-Corner Peppol from January, 30 June 2026.