In February 2026, we covered the introduction of mandatory electronic invoicing in Belgium and the changes it would bring for businesses.<\/p>\n
In our first article on Belgium, we outlined the main challenges of the reform: EN 16931, structured formats, the Peppol network, ERP integration, VAT data and flow management.<\/p>\n
Read the article: Electronic invoicing in Belgium: What Your Business Needs to Know<\/a><\/em><\/p>\n<\/p>\n Since 1 January 2026, structured e-invoicing has been mandatory in Belgium for B2B transactions falling within the scope of the reform.<\/strong><\/p>\n The invoices concerned must be structured and enable automated processing. A simple PDF sent by email no longer meets this definition.<\/p>\n A few months after the implementation of the electronic invoicing in Belgium, the issue is therefore no longer simply one of regulatory preparation. Businesses must now ensure that new flows, new controls and new interactions between their systems operate effectively on a day-to-day basis.<\/p>\n And at the heart of this transformation lies Peppol<\/strong>.<\/p>\n The question is no longer simply: \u201cHow do we prepare for e-invoicing?\u201d<\/strong><\/p>\n It is now: \u201cWhat happens once e-invoicing becomes an operational reality?\u201d<\/strong><\/p>\n<\/p>\n Since 1 January 2026<\/strong>, Belgian VAT-registered businesses covered by the scheme have been required to use structured electronic invoices for B2B transactions falling within the scope of the obligation. Exceptions apply, notably depending on the nature of the transaction and the taxpayer\u2019s situation.<\/p>\n A structured electronic invoice is not simply a PDF sent by email.<\/p>\n The Belgian administration defines a structured electronic invoice as an invoice that enables automated and electronic processing<\/strong>. The invoices concerned must comply with the European standards EN 16931-1 and CEN\/TS 16931-2<\/strong> and may be issued in Peppol-BIS<\/strong> format.<\/p>\n Structured electronic invoices must be capable of being sent and received via the Peppol<\/strong> network, except where another format and another transmission method compliant with the European standard have been agreed between the parties.<\/p>\n The change therefore goes much further than simply changing the format.<\/p>\n The invoice becomes a data flow designed to be processed by IT systems<\/strong>.<\/p>\n The obligation is also accompanied by a sanctions framework. A new penalty is now in effect for businesses that do not have the technical means to issue and receive structured electronic invoices. The penalty for a first offence is 1,500\u20ac, 3,000\u20ac for a second offence and 5,000\u20ac for subsequent offences<\/strong>. These amounts are in accordance with the arrangements set out in the Royal Decree of 8 July 2025.<\/p>\n The focus has therefore shifted: the issue is no longer simply preparing for the transition, but ensuring that the flows actually work on a day-to-day basis.<\/p>\n<\/p>\n This is one of the most interesting developments to observe since the reform came into place.<\/p>\n Belgium has made Peppol a central component of its B2B e-invoicing framework<\/strong>. The network enables companies\u2019 software systems to exchange structured electronic invoices securely and interoperably.<\/p>\n The Belgian administration notably recommends a \u201cPeppol-first\u201d<\/strong> approach: when a business partner is connected to the network, the software should automatically prioritise sending via Peppol. Registration on the network also signals to business partners that a company prioritises Peppol for receiving invoices.<\/p>\n However, it is important to distinguish between registration on the network<\/strong> and actual use of the network<\/strong>.<\/p>\n A Peppol ID<\/strong> identifies a participant on the network. In Belgium, the company number is the reference identifier to be registered; other identifiers, such as a VAT number, IBAN, GLN or DUNS identifier, may also be used as additional identifiers on a voluntary basis.<\/p>\n Data relating to participants or identifiers therefore does not necessarily represent a count of unique businesses, nor does it directly measure the number of invoices actually exchanged.<\/p>\n The Peppol Directory<\/strong> itself states that keeping the information up to date is the responsibility of SMP service providers and that publication is currently not mandatory for all participants. Not all registered participants are therefore necessarily visible in the directory.<\/p>\n It is therefore preferable to regard statistics relating to participants and identifiers as indicators of the size and dynamics of the network<\/strong>, rather than as a direct measure of operational adoption.<\/p>\n The underlying trend nevertheless remains significant:<\/p>\n Peppol is becoming a central infrastructure for B2B electronic exchanges in Belgium.<\/strong><\/p>\n<\/p>\n One of the developments to watch over the coming months is how businesses will use this infrastructure beyond the regulatory requirement alone.<\/p>\n Initially, adoption is largely driven by regulation.<\/p>\n An obligation comes into force.<\/p>\n Businesses need to equip themselves.<\/p>\n Software vendors adapt their solutions.<\/p>\n Service providers connect their clients.<\/p>\n Business partners adapt.<\/p>\n But when many players are connected to the same infrastructure, it can also become a preferred operational channel.<\/p>\n This logic is already encouraged by the Belgian framework: the administration recommends a \u201cPeppol-first\u201d<\/strong> approach when a business partner is connected to the network. The extent to which this dynamic develops over time nevertheless remains to be observed.<\/p>\n Registration statistics alone are not sufficient to demonstrate that businesses are actually prioritising Peppol in their exchanges or to measure the volumes genuinely exchanged.<\/p>\n The question then becomes:<\/p>\n What happens when an infrastructure introduced through regulation gradually becomes an exchange channel integrated into business processes?<\/strong><\/p>\n<\/p>\n A structured invoice is designed to enable automated processing<\/strong> of data. This is precisely one of the fundamental differences compared with a traditional PDF document.<\/p>\n An electronic invoice can therefore be integrated into a company\u2019s management systems rather than simply being received as an attachment requiring manual processing.<\/p>\n The Belgian government itself highlights the opportunities created by electronic invoice exchange in terms of automated processing<\/strong> and monitoring of invoicing-related processes.<\/p>\n For a finance department, the question therefore gradually becomes:<\/p>\n \u201cHave we simply automated the transmission of the invoice, or have we actually automated the process behind it?\u201d<\/strong><\/p>\n This is where much of the potential value of the reform lies.<\/p>\n<\/p>\n A structured invoice can be generated by a management system, checked, transmitted through an interoperable network and then integrated into the recipient\u2019s system.<\/p>\n The official Belgian website describes e-invoicing as an exchange between the software systems of two businesses.<\/p>\n In a properly integrated environment, the process can therefore be viewed as a chain:<\/p>\n Of course, not all of these steps are automatically performed by Peppol itself.<\/p>\n Peppol provides interoperability and data transport; process automation then depends on the company\u2019s software architecture.<\/strong><\/p>\n This is why connecting to Peppol should not be viewed as an isolated IT project.<\/p>\n The real issue is the integration of e-invoicing into the existing financial environment.<\/p>\n<\/p>\n A structured invoice relies on structured data.<\/p>\n Businesses must therefore have sufficiently reliable master data to enable invoices to be issued and received: partner identification, VAT data, billing information and other data required to prepare the invoice.<\/p>\n The Belgian administration also recommends that businesses assess their invoicing and accounting systems and, where necessary, adapt them so that they can send and receive structured electronic invoices.<\/p>\n Data quality therefore becomes an important prerequisite for automation.<\/p>\n Connecting to the Peppol network does not replace the company\u2019s financial system.<\/p>\n The software used must be capable of sending and receiving structured invoices via Peppol. The Belgian administration also recommends that businesses already using an ERP check with their software provider whether it can manage these flows.<\/p>\n The challenge is therefore to connect e-invoicing with existing processes:<\/p>\n The more advanced the integration, the more the business can take advantage of the opportunities offered by structured data.<\/p>\n Automation does not mean that every situation will be handled automatically.<\/p>\n A financial architecture must, in particular, be able to manage non-compliant invoices, incorrect data or situations requiring human intervention.<\/p>\n This logic follows, among other things, from the technical requirements applicable to structured electronic invoices: they must comply with precise semantic, syntactic and transmission rules. Failure to comply with certain obligations may also result in penalties.<\/p>\n Process performance therefore depends not only on the ability to process standard cases automatically.<\/p>\n It also depends on the ability to identify and resolve exceptions quickly<\/strong>.<\/p>\n The success of the transition does not depend entirely on the sender.<\/p>\n It also depends on the ability of customers and suppliers to receive and process structured invoices.<\/p>\n The Belgian administration states that a business registered on Peppol signals to its business partners that it prioritises this channel for receiving invoices. It also recommends a \u201cPeppol-first\u201d<\/strong> approach for outgoing invoices when the partner is connected.<\/p>\n The more partners that are accessible on the network, the more relevant it becomes to integrate this information directly into invoicing processes and partner master data.<\/p>\n<\/p>\n The entry into force of B2B e-invoicing does not necessarily mark the end of the regulatory transformation.<\/p>\n E-reporting<\/strong> is already a development to monitor.<\/p>\n On 18 July 2026<\/strong>, the Belgian Council of Ministers approved a draft bill<\/strong> aimed at introducing an obligation to electronically report certain invoicing data to the administration and abolishing the obligation to file the annual list of taxable customers.<\/p>\n The proposed framework provides for a form of \u201cnear real-time\u201d<\/strong> electronic reporting of certain mandatory invoice data by both the supplier or service provider and its contracting party.<\/p>\n At this stage, it is important to refer to this as a draft bill<\/strong>: the text must still go through the legislative and regulatory process.<\/p>\n It would therefore be premature to present a definitive implementation timetable.<\/p>\n For businesses, however, the message is important: 2026 compliance can provide the technological foundation for future tax obligations.<\/strong><\/p>\n The structured data produced within invoicing systems may therefore become increasingly important in regulatory reporting processes.<\/p>\n<\/p>\n This development is also reflected in the governance of the network.<\/p>\n On 25 June 2026<\/strong>, the SPF BOSA<\/strong> (Belgian Federal Public Service Policy and Support)<\/em> announced that the SPF Finances will take over the role of Belgian Peppol Authority from 2027<\/strong>. BOSA currently performs this role.<\/p>\n The transfer is notably linked to the need to strengthen tax expertise around the network, particularly in preparation for e-reporting. SPF Finance will therefore become the central point of contact for e-invoicing and e-reporting.<\/p>\n This change does not, in itself, alter businesses\u2019 operational obligations.<\/p>\n It does, however, illustrate a change in the role of Peppol within the Belgian ecosystem: the network now forms the basis for electronic invoicing and future reporting obligations.<\/p>\n Peppol is therefore no longer simply a technical exchange channel.<\/p>\n It is gradually becoming a component of the digital infrastructure underpinning B2B electronic exchanges and future Belgian tax reporting developments<\/strong>.<\/p>\n<\/p>\n Another consequence of the entry into force in January 2026 is that it paves the way for future developments in the Belgian framework.<\/p>\n E-reporting is notably the next major development to monitor.<\/p>\n The first phase in 2026 does not yet include the electronic reporting framework envisaged by the draft bill adopted in July. This aims to introduce the electronic transmission of certain invoicing data to the administration as part of a near real-time<\/strong> reporting model.<\/p>\n This development is important for businesses that are already working on structuring their flows.<\/p>\n A structured invoice is, in fact, a source of data that can be directly used by financial systems and, ultimately, potentially by regulatory reporting mechanisms.<\/p>\n In other words: 2026 compliance can become the technological foundation for tomorrow\u2019s tax obligations.<\/strong><\/p>\n<\/p>\n Belgium is particularly interesting to observe as France enters the operational phase of its own reform.<\/p>\n Since 1 September 2026<\/strong>, all French businesses liable for VAT have been required to be able to receive electronic invoices. As of the same date, large companies and mid-sized companies (ETIs) must also be able to issue electronic invoices. SMEs, small businesses and micro-enterprises will have to be able to issue electronic invoices from 1 September 2027<\/strong>. France nevertheless relies on an architecture that differs from Belgium\u2019s.<\/p>\n The French framework is based on state-approved platforms<\/strong>. From 1 September 2026, taxable businesses must use an approved platform to receive and transmit their electronic invoices, as well as the invoicing, transaction and payment data covered by the framework.<\/p>\n Approved platforms notably act as intermediaries in the exchange of invoices and in the transmission of certain data to the tax authorities.<\/p>\n Peppol may play a role within the French ecosystem, but the French model should therefore not be equated with the Belgian model.<\/p>\n For groups with several European subsidiaries, this difference in architecture is important.<\/p>\n The real challenge then becomes:<\/p>\n How can we build an invoicing architecture capable of managing multiple regulations, multiple formats, multiple networks and multiple reporting obligations?<\/strong><\/p>\n<\/p>\n The first few months of the Belgian reform already make it possible to identify several key insights.<\/p>\n Being able to issue and receive a structured electronic invoice meets a regulatory requirement.<\/p>\n But this does not necessarily mean that the entire financial process has been optimised. Integration into invoicing and accounting systems is a separate step. The Belgian administration also recommends that businesses check whether their software is capable of sending and receiving structured invoices via Peppol.<\/p>\n A structured electronic invoice relies on data that can be processed automatically. Data reliability therefore becomes an important condition for automating processes. The European standard imposes specific requirements relating to semantics and syntax.<\/p>\n The network provides the infrastructure on which the exchange of structured electronic invoices in Belgium is based. The administration also recommends a \u201cPeppol-first\u201d<\/strong> approach when a business partner is connected.<\/p>\n E-invoicing must be connected to the systems that manage the company\u2019s invoicing, accounting and financial processes. The Belgian administration recommends that businesses using an ERP check its ability to send and receive structured electronic invoices.<\/p>\n Automation does not eliminate exceptional cases. It must make it possible to identify and handle them effectively, particularly when data or technical requirements are not met. Belgian rules notably establish precise requirements relating to the semantics, syntax and transmission of structured invoices.<\/p>\n The Belgian draft legislation on e-reporting shows that regulatory requirements could gradually extend beyond the issuing and receiving of invoices.<\/p>\n<\/p>\n Almost 9 months after the introduction of mandatory B2B e-invoicing in Belgium, one initial lesson can already be drawn.<\/p>\n Regulation drives adoption.<\/strong><\/p>\n But the value of the reform goes beyond compliance.<\/p>\n By turning invoices into structured data and integrating them into an interoperable network such as Peppol, Belgium is creating the conditions to take financial process automation further. The Belgian government itself highlights the opportunities offered by electronic exchanges for automated processing.<\/p>\n The real change, however, lies elsewhere.<\/p>\n E-invoicing is beginning to move beyond the simple transmission of a document to become data integrated into an end-to-end financial process<\/strong>.<\/p>\n This is the shift that now deserves the attention of finance and IT teams.<\/p>\n The question is therefore no longer simply: \u201cAre we compliant?\u201d<\/strong><\/p>\n It is now: \u201cHow can we leverage this infrastructure to genuinely automate our financial processes?\u201d<\/strong><\/p>\n For Belgian businesses, the next challenge is to move from adoption to industrialisation. The integration of Peppol into ERP systems, data quality, exception management and process automation will increasingly determine the real value businesses can derive from the reform.<\/p>\n At Deveho<\/strong>, we support businesses in transforming their invoicing processes and integrating e-invoicing requirements into their ERP environments.<\/p>\n The objective: not simply to make your business compliant, but to embed e-invoicing into more reliable, more automated financial processes that are better prepared for future regulatory developments across Europe.<\/strong><\/p>\n <\/p>\n Related sources:<\/em><\/strong><\/p>\n <\/p>\n Read also:<\/strong><\/em><\/p>\n Electronic invoicing in Belgium: What your company must anticipate today<\/a><\/p>\n<\/blockquote>\n<\/h3>\n
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1. Data quality becomes the key<\/h4>\n
2. ERP integration becomes central<\/h4>\n
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3. Exception management becomes a process in its own right<\/h4>\n
4. Partner onboarding becomes strategic<\/h4>\n
Compliance is the first step<\/h4>\n
Data is becoming an operational asset<\/h4>\n
Peppol is becoming a structuring element of the Belgian model<\/h4>\n
The ERP becomes a central component of the framework<\/h4>\n
Exceptions must be anticipated<\/h4>\n
Future developments must be taken into account<\/h4>\n
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