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Mandatory use of structured electronic invoices as from 2026

As from 1 January 2026, structured electronic invoicing will be compulsory for nearly all transactions between Belgian enterprises liable to VAT (B2B).

The obligation to issue structured electronic invoices does not apply to supplies of goods or services provided to individuals for their private use (“B2C” or “business-to-consumer”).

For invoicing to public authorities (“B2G” or “business-to-government”), electronic invoicing is compulsory for contracts published after 1 March 2024. Specific regulations (Dutch - French) apply at this level.

(1) The obligation generally applies to contracts with a value of EUR 3,000 or more (excluding VAT). However, contracting authorities can be stricter by including a provision to this effect in the contract documents. Federal contracting authorities have also had to impose electronic invoicing below €3,000 since 1 March 2024. In het Staatsblad: koninklijk besluit 'borgtocht en elektronische facturering' | BOSA (belgium.be), Au moniteur : l’arrêté royal « cautionnement et facturation électronique » | BOSA (belgium.be).
 

  • For which B2B transactions does the obligation not apply?

    The obligation for structured electronic invoicing will almost always apply to transactions between two Belgian enterprises liable to VAT.

    There are some limited exceptions to this principle:

    • It is not compulsory to send structured electronic invoices for:
      • bankrupted persons liable to tax;
      • businesses that only carry out exempted transactions pursuant to Article 44 of the VAT Code;
      • persons liable to tax and not established in Belgium, without a permanent establishment ;
      • persons liable to tax on a flat rate basis (Article 56 of the VAT Code - will end on 1.1.2028 at the latest).
    • It is not mandatory to be able to receive structured electronic invoices for:
      • enterprises that only carry out exempted transactions pursuant to Article 44 of the VAT Code.
    • It is not compulsory to send or receive structured electronic invoices if the transaction is exempted pursuant to Article 44 of the VAT Code.

  • Can I use structured electronic invoices if they are not compulsory?

    Anyone is free to use structured electronic invoices on a voluntary basis, even in situations where they are not legally required. As there is no obligation for this transaction, your client is thus not required to be able to receive a structured electronic invoice for this operation. Therefore, this will only be possible if both parties agree to work this way.

  • Is self-billing authorised?

    The rules on this subject remain unchanged. Self-billing remains authorised provided that there is a prior agreement between the two parties and that each invoice is subject to an acceptance procedure by the person liable to tax carrying out the supply of goods or providing services. Self-billing will soon be possible via Peppol.

  • Can electronic and paper invoices coexist?

    Till 31 December 2025, you can use both electronic invoices (with the consent of the recipient) and paper invoices. As from 1 January 2026, structured electronic invoicing will be compulsory for transactions between Belgian enterprises liable to VAT (B2B). If you wish, you can also send a PDF or paper version of the invoice to your client, but the structured electronic invoice is the only legally compliant invoice.

  • Are there support measures?

    To offset the costs you may incur in making technical adaptations, we have planned two tax support measures:

    • As from 1 January 2025, the investment deduction for digital investments will rise to 20 %.
    • For the period liable to tax 2024-2027, small SMEs and the self-employed people who use subscription formulas can mention an increased deduction of costs reaching 120 % for invoicing programmes. The extra cost that will be paid for an existing software subscription due to electronic invoicing (preparing, sending and receiving electronic invoices in a structured form) is eligible for the increased deduction of costs of 120 %, provided that this extra cost is indicated separately on the invoice.

  • Deducting VAT and/or reporting costs as professional expenses as a self-employed person

    As a self-employed person, you would like to deduct the VAT mentioned in your incoming business invoices (B2B). As from 1 January 2026, this will only be possible by means of the structured electronic invoices you have received and which contain all mandatory information (Article 5, §1, of Royal Decree No. 1 of 29.12.1992).

    You would like to declare as professional expenses part of the costs mentioned in the private invoices (B2C) you have received (e.g. of gas, electricity, water ...). You can do so by means of both paper and electronic invoices received. Those invoices in fact are not subject to the new obligation to issue and receive structured electronic invoices.