E-invoicing in Belgium: What you need to know

E-invoicing in Belgium: What you need to know

The use of e-invoices in the country started way back in 2013 when the government announced that e-invoicing was as effective as paper invoices. In the context of the public sector, all central and federal authorities are required to receive e-invoices. Suppliers of these entities are also subject to this requirement. Furthermore, the country's parliament has passed a proposal allowing for B2B electronic invoicing.

Additionally, note that these e-invoices are issued in a pre-defined structure that follows specific transmission standards in Belgium. Therefore, invoices must be issued and transmitted in a structured format that enables automatic and electronic processing. Moreover, sending a PDF using email is no longer considered an electronic invoice because PDFs are unstructured documents and are difficult to extract and process data automatically. Keep on reading to get a full grasp of the e-invoicing updates in Belgium.

Timeline for the mandatory e-invoicing implementation in Belgium

Contrary to many EU countries, Belgium has no plans for phase-wise implementation of mandatory e-invoicing. Instead, the mandate will be introduced in a single phase, starting from January 1, 2026. As of now, the exact criteria for entities falling under each level are not clear. Moreover, unlike other countries in the EU, no new rules for B2G, B2C, or the reporting of invoice data have been proposed in the legislation yet.

What is the scope of e-invoicing in Belgium?

The scope of the mandate includes:

• Taxable entities engaged in exclusive transactions exempted from VAT under Article 44 of the Belgian VAT Code (cultural activities, special medical services, and so on)
• Taxable individuals using a flat-rate program following Belgian VAT Code article 56
• Customers of the structured e-invoice must be taxable persons with a Belgian VAT number or are under the obligation to register their VAT in the country
• Transactions related to the supply of goods outside the country for which a Belgian tax ID is not required
• Taxable individuals in a state of bankruptcy 
• The transaction must be a taxable transaction located domestically in Belgium 

On a specific note, B2G e-invoicing in Belgium is mandatory for contracts published after March 1, 2024. Also, keep in mind that B2C transactions are not included in the e-invoicing plans.

Understanding the e-invoicing format for Belgium 

The mandatory e-invoicing requires all established companies to issue invoices in a pre-defined format that follows specific transmission standards in the country. The proposed format is PEPPOL-BIS UBL, which follows the four-corner model for exchanging e-invoices. The PEPPOL-BIS complies with the EU standard format EN-16931. However, the entities involved can select the agreed-upon alternative system that is compliant with the European standard format.

Originally established for B2G e-invoicing, the PEPPOL (Pan-European Public Procurement Online) format has gradually expanded to B2B use cases. However, it has yet to form a basis of a countrywide B2B e-invoicing mandate, so that some issues may arise during the implementation of the mandate.

What is the electronic invoicing process in Belgium?

E-invoicing in Belgium typically occurs through the Mercurius platform, which was created by the country's government and is linked to the PEPPOL network. When exchanging invoices using Mercurius, you must adhere to the PEPPOL BIS 3.0 document format. Businesses planning to send invoices to public authorities in the country can do so through two different methods:

Manual input using Mercurius 

The Mercurius platform's manual invoice submission form is one of the most basic approaches for submitting electronic invoices. The platform not only allows companies to send structured invoices but also lets senders, receivers, and intermediaries track the status of sent documents.

Even though this is a popular option among suppliers who don't yet have EDI capability or don't have multiple orders from the country's public organisations, it is not an ideal option for other businesses because of the amount of manual effort involved. Furthermore, only organisations based in Belgium can use this option.

Though PEPPOL

The second approach for e-invoicing in Belgium is through the PEPPOL network. In contrast to the Mercurius platform, the exchange of documents using PEPPOL is completely automated. That's why companies sending invoices through PEPPOL can experience the cost and time-saving benefits of automated exchange.

PEPPOL employs the four-corner model, where the sender, the sender's access point provider, the receiver's access point provider, and the receiver themselves are the corners. The four-corner model makes exchanging documents easier for any PEPPOL-enabled organisation with any other linked business.

Similar to sending electronic invoices, receiving invoices involves two different approaches:

Using the PEPPOL network

Companies connected to a PEPPOL access point don't have to worry about receiving structured electronic documents. However, their chosen service provider must ensure that the required mapping is in place to convert the incoming invoices into a format that the recipient ERP system will understand.

Note that not all PEPPOL access points provide the same service. For instance, not all providers are AS4 compliant and may not offer API connections, which provide numerous benefits, such as improved data visibility and seamless error correction. 

Hermes 

In addition to Mercurius for e-invoicing in Belgium, the government has developed a platform called Hermes, which helps convert PEPPOL BIS documents into a human-readable and emailable format (XML in PDF format). Just like the Mercurius approach, Hermes does not allow the recipient to leverage full automation capabilities, as it still involves manual work on the receiver's part to process invoices. However, providing platforms like these was believed to allow public organisations to shift to e-invoicing more quickly.

Are there any penalties for non-compliance with the e-invoicing mandate?

In the context of public procurement, all Belgian public organisations are already obliged to be able to receive and process e-invoices, which makes it mandatory for all federal government suppliers to send e-invoices. However, failing to follow the mandate can lead to hefty penalties, such as:

• Issuing invoices that are non-compliant may result in financial penalties
• Customers may experience challenges recovering VAT if they do not receive invoices in an accurate format
• Customers may refuse to pay if the invoices are not in compliance with the new regulations, which will reflect in reputational damage and impact on the cash flow

Conclusion 

This article highlights the key e-invoicing updates in Belgium. The best thing you can do now as an organisation is to prepare for this change. While preparing your business for this new shift, consider connecting with an expert to create the necessary structure for accurately sending and receiving e-invoices. After all, with the right partner, you will be able to enjoy the benefits of structured document exchange in the country.