Belgium E-Invoicing Compliance

Who has to issue structured e-invoices in Belgium?

Every business established in Belgium and registered for Belgian VAT must issue and receive structured electronic invoices for domestic B2B transactions. That includes foreign companies with a Belgian fixed establishment, and VAT groups. It has applied since 1 January 2026, and since the tolerance period closed on 31 March 2026 it has been enforced without exception.

Three cases fall outside it. B2C invoices are not covered. Businesses whose activity is exempt under Article 44 of the Belgian VAT Code are out of scope. And a non-resident business with no fixed establishment in Belgium is not obliged to issue structured invoices — though it will still be sent them, so it needs a way to receive and process what arrives.

If you are a foreign supplier selling into Belgium, that last point is the one that catches people. Your Belgian customers are now obliged to receive structured invoices, and increasingly expect to be invoiced the same way. See our full write-up of the Belgian B2B mandate for the detail.

Which format does Belgium require?

Peppol BIS Billing 3.0, in UBL 2.1, compliant with the European standard EN 16931. A PDF is not a structured invoice, and neither is a PDF with an XML file attached alongside it — the invoice itself has to be machine-readable.

Belgium deliberately publishes no national CIUS. The European Commission confirms no additional national specification exists, which makes Belgium unusually cheap to comply with: plain Peppol BIS 3.0 is the whole requirement. Compare that with Germany’s XRechnung and ZUGFeRD or France’s Factur-X and PPF model, both of which layer national requirements on top.

Document type codes follow UNCL1001: 380 for a commercial invoice and 381 for a credit note. Corrections must be issued as structured credit notes, not as an emailed PDF. If you are unsure how Peppol profiles relate to the newer PINT specifications, we explain the difference here.

The identifier: why Belgian companies use scheme 0208

On the Peppol network a Belgian business is identified by its enterprise number from the Crossroads Bank for Enterprises (KBO/BCE) — ten digits, under Peppol scheme 0208. Service providers are contractually obliged to register Belgian participants this way; using the VAT scheme 9925 instead is a breach of the provider’s agreement, not a stylistic choice.

The number carries a check digit: the last two digits are 97 − (first eight mod 97). Peppol validates it, and an invoice quoting a malformed enterprise number is rejected outright with rule PEPPOL-COMMON-R043. GoRoute enforces the scheme and the check digit at registration, so a bad identifier is caught before it reaches the network rather than after your invoice bounces. Other avoidable rejections are covered in invoice validation errors you can prevent.

Hermes has closed — what replaced it

Until recently every Belgian company was reachable on Peppol by default, because BOSA pre-registered them all in the Hermes SMP and forwarded anything undeliverable by email. Hermes was decommissioned on 31 December 2025, with read-only access until March 2026.

The practical consequence is easy to miss: a Belgian buyer who has not appointed a Peppol service provider is now genuinely unreachable, and a send to them will fail at lookup. That is a correct outcome rather than a fault. If you are choosing a provider for the first time, how to choose a Peppol access point sets out what actually matters, and our onboarding checklist for finance teams covers the internal work.

What are the penalties for non-compliance?

Administrative fines escalate per offence within a three-month window: €1,500 for the first, €3,000 for the second and €5,000 for the third. The clock resets after three months without a further breach.

The larger commercial risk is not the fine. A buyer obliged to receive structured invoices may simply refuse a PDF, and an invoice that cannot be booked does not get paid — so the working-capital cost of non-compliance usually arrives before any penalty does.

2028: near real-time e-reporting and the 5-corner model

From 1 January 2028 Belgium adds near real-time e-reporting on a five-corner Peppol model. The tax authority becomes an additional participant, receiving structured invoice data shortly after issuance rather than in a periodic return. Reporting is transaction by transaction, it replaces the annual customer listing, and both supplier and customer report separately.

Notably, Belgium has confirmed no platform accreditation will be required, unlike France. Your provider does not need a Belgian licence — it needs to be a certified Peppol access point that can file both sides correctly.

This is the same architecture GoRoute already operates in Oman, where both the supplier’s and the buyer’s provider file a tax document for the same invoice and a deterministic UUID lets the authority correlate the two. The direction of travel across the EU is set by ViDA; Belgium is simply early.

Can a foreign provider handle Belgian e-invoicing?

Yes. Belgian law distinguishes providers established in Belgium, which hold a service agreement with FPS BOSA, from providers established elsewhere, which are approved “under an equivalent service contract concluded with the competent administration of the place of establishment of that service provider acting as a Peppol authority there.”

In plain terms: a certified Peppol access point does not need a Belgian entity or BOSA accreditation to serve Belgian businesses. You are free to choose on capability and price rather than postcode. GoRoute operates its own certified access point and SMP, so your invoices are not relayed through a third party’s infrastructure — see the API integration guide or test it free in the sandbox.

Getting started: a realistic sequence

1. Confirm your enterprise number and check the mod-97 check digit. This is your Peppol identity under scheme 0208.
2. Appoint an access point and have it register you on the network. Registration is the provider’s obligation, not yours.
3. Connect your ERP or accounting system. Post your existing invoice data over a REST API or an existing connector — you should not have to author UBL by hand.
4. Validate before you send. Run real documents against EN 16931 and the Peppol rules in a test bed first; validation failures are far cheaper to find there.
5. Handle inbound too. The mandate is symmetrical — you must be able to receive structured invoices, not only issue them.
6. Plan for 2028 while you are in the code, rather than reopening it in eighteen months.