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E-invoicing mandatory in Belgium

Everything you need to know about the obligation of e-invoicing in Belgium
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Everything you need to know about the obligation of e-invoicing in Belgium

Today, e-invoicing is already mandatory in Belgium in the Business-to-Government (B2G) context, i.e. when invoicing to local and federal governments.

The Flemish government was the first to introduce this obligation in 2017.

Since November 2022, the federal government has introduced the obligation in three phases and from November 2023 it will apply to all procurement.

You send structured invoices via Peppol to the government. If you do not have the right software to deliver Peppol invoices to the government, you can upload the invoice manually via the Mercury portal.

The latter method only makes sense if you only send a limited number of invoices to the government or as a transitional phase, giving you time to invest in an automated solution. Because that investment will eventually be necessary.

E-invoicing will become mandatory for all businesses in Belgium from 2024

Besides the B2G obligation, the government is currently working on a bill for the obligation of electronic invoicing in the Business-to-Business (B2B) context.

Finance minister Vincent Van Peteghem included this obligation in his October 2022 policy note (see to reduce the VAT gap.

The VAT gap is the amount Belgium loses annually due to, among other things, inefficient collection, administrative errors, fraud, evasion and so on.

This amount is estimated at more than €4 billion a year.

In the first phase of the tax reform, as published in March 2023 (see, the minister reiterates plans for e-invoicing and e-reporting.

The bill is not yet final, but the following plans have already been communicated:

  • The final format of a structured electronic format and the method of transmission are yet to be determined, but it is expected that Peppol will become the standard.
  • Paper and PDF invoices will be dropped, but exceptions may still be allowed.
  • Implementation will take place in three phases:
  • From July 2024, all businesses must receive e-invoices.
  • Sending e-invoices will gradually become mandatory: first, large enterprises (turnover > 9 million euros) will be subject, then SMEs (turnover > 700,000 euros) and eventually any business.

Does this mean the end of the paper or PDF invoice?

Our expectation is not. By definition, the phased rollout means that you will receive invoices in different forms and formats, as is already the case today, but the share of e-invoices will grow strongly and the volume of paper and PDF invoices will decrease.

How fast paper and PDF invoices will disappear no one can accurately predict, but we estimate that it will take another 5 years. Some arguments for this are:

  • The Flemish government still does not receive 100% e-invoices today, despite the obligation since 2017 (already 6 years ago).
  • Despite the upcoming obligation, companies and organisations will need time to invest in resources and knowledge to support e-invoicing.
  • The obligation only applies to Belgian companies. If you trade with foreign countries, you will still receive/send PDF invoices.

Are you ready for e-invoicing yet?

Our advice is to prepare for the new legislation now and take the necessary steps to be ready by July 2024.

Every organisation deals with different business systems that consume or generate incoming or outgoing invoice information. The transition from paper/email invoices to e-invoices can have a big impact.

You will suddenly have to deal with e-invoices that cannot be processed by a human being in addition to the current paper and PDF invoices. You can’t just print these and deal with them on paper because these invoices are incomprehensible to an ordinary user.

Amista offers with RecoMatics Document Suite a standard solution for invoice processing, regardless of the source format (paper, PDF or e-invoice).

Let’s prepare you together for the Peppol obligation

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