For the past few years, Belgium has been working per Directive 2014/55/EU to ensure that all business-to-government (B2G) procurement uses e-invoices rather than unstructured or paper invoices.
Adopting the EU directive concerning invoicing will help it achieve significant savings. Furthermore, the country will benefit from an electronic record of sales invoices (including VAT owed), give it greater visibility of taxes it is due to collect, and make it easier to identify and act upon instances where these taxes are not submitted to the tax authority.
This mandatory e-invoicing regulation will soon take effect. Hence, businesses operating in Belgium must adapt to these changes to ensure compliance and maintain operational efficiency.
Today's guide will explore Belgium's e-invoicing approach and provide key insights to help businesses stay compliant.
Overview of e-Invoicing in Belgium
The use of e-invoices in Belgium began in 2013 when the government announced that e-invoicing was as legitimate as paper invoices.
In the public sector, all federal and central authorities are required to receive e-invoices. Suppliers of these public entities, including those in the following regions: Wallonia, Flanders, and Brussels, are also subject to this duty.
All suppliers to public administrations are required to issue electronic invoices. Furthermore, the Belgian Parliament has passed the proposed legislation allowing for B2B electronic invoicing in the country.
Also, note that e-invoices are issued in a pre-defined format following specific transmission standards in Belgium. Hence, invoices must be issued and transmitted in a structured electronic form that allows automatic and electronic processing.
Sending a PDF via email no longer suffices as an electronic invoice because PDFs are unstructured documents and make it difficult to extract and process data automatically.
What is the timeline for the implementation of mandatory e-invoicing in Belgium?
Unlike many EU countries, Belgium has no phased approach to implementing mandatory e-invoicing. Instead, the mandate will be introduced in a single phase beginning January 1st, 2026.
The exact criteria for entities falling under each level are unknown (presumably, the initial phase will contain only the largest companies). Also, unlike other EU countries, no new rules about B2G, B2C, or reporting of invoice data have yet been proposed in the legislation.
Scope of e-invoicing in Belgium
As of 2024, the scope of the mandate includes:
- Taxable individuals engaged in exclusive transactions exempted from VAT under Article 44 of the Belgian VAT Code (Specific medical services, cultural activities, etc.).
- Taxable individuals using a flat-rate program following Belgian VAT Code Article 56.
- Taxable individuals in a state of bankruptcy.
- Transactions concerning the supply of goods outside of Belgium for which a Belgian tax ID is not required.
- Customers of the structured electronic invoice must be taxable persons with a Belgian VAT number or are under the obligation to register their VAT in Belgium.
- The transaction shall be a taxable transaction located domestically in Belgium.
On a separate note, B2G e-invoicing in Belgium is mandatory for contracts published after March 1st, 2024. Also, note that B2C transactions are excluded from the e-invoicing plans.
E-invoicing format in Belgium
In Belgium, mandatory e-invoicing requires all established businesses to issue invoices in a pre-defined format following specific transmission standards. The proposed format is PEPPOL-BIS UBL, which follows the four-corner model for exchanging e-invoices between taxpayers.
The PEPPOL-BIS complies with the EU standard format EN-16931. However, parties may choose to opt for an agreed-upon alternative system that is compliant with the European standard format.
The PEPPOL (Pan-European Public Procurement Online) format, originally established for business-to-government (B2G) e-invoicing, has gradually expanded to business-to-business (B2B) use cases.
However, it has yet to form the basis of a nationwide B2B e-invoicing mandate such as that suggested here, so there is still certainly room for issues to arise during the mandate's implementation.
Electronic invoicing process in Belgium
The electronic invoicing process in Belgium generally occurs via the Mercurius platform, developed by the Belgian government and linked to the PEPPOL network.
When exchanging invoices and credit notes using Mercurius, they must follow the PEPPOL BIS 3.0 document format. Companies planning to send invoices to public entities in Belgium can do so via two different methods:
Manual input via Mercurius
The most basic approach is using the Mercurius platform's manual invoice submission form. In addition to allowing companies to send structured invoices and credit notes, Mercurius's interface lets senders, receivers, and intermediates track the status of sent documents.
While this option is popular among suppliers who do not yet have EDI capability or who do not have multiple orders from Belgian public organizations, it is impractical for other businesses due to the amount of manual effort involved. Furthermore, only Belgian companies can use this method.
Via PEPPOL
The second approach is to send documents via the PEPPOL network. Unlike transmission directly via the Mercurius platform, the exchange of documents via PEPPOL is completely automated.
Hence, businesses sending invoices via PEPPOL can experience the cost and time benefits of an automated message exchange. To send documents via PEPPOL, all you need to do is connect to a certified PEPPOL Access Point, like StoreCove.
PEPPOL employs the "four corner model," wherein the sender, sender's access point provider, receiver's access point provider, and receiver themselves are the "corners," as shown in the following illustration.
This method makes it possible to trade papers with as many PEPPOL-connected organizations as you want. Rather than setting up point-to-point connections or having both sender and receiver have the same EDI service provider, the four-corner model makes exchanging documents easier for any PEPPOL-enabled business with any other linked business.
As with sending structured electronic invoices, receiving electronic invoices can be handled in one of two ways:
Via PEPPOL
Businesses connected to a PEPPOL access point don't have to be concerned about receiving structured electronic documents. Their chosen service provider must ensure that the required mapping is in place to convert the incoming documents into a format the recipient ERP system will understand.
It is important to remember that not all PEPPOL access points provide the same service. For example, not all providers are currently AS4 compliant. Further, many do not offer API connections, which provide many significant benefits, including vastly improved data visibility and easy error correction.
Hermes
In addition to Mercurius, the Belgian government has created a platform known as Hermes, which converts PEPPOL BIS documents into human-readable, emailable form (XML in PDF format).
Similar to sending bills directly through Mercurius, this approach does not enable the recipient to take advantage of full automation since it still involves manual work on the receiver's part to process the invoice.
However, providing such a platform was believed to allow public organizations to switch to e-invoicing more quickly.
What is the penalty for not adhering to Belgium's e-invoice mandate?
All Belgian public organizations are already obliged to be able to receive and process e-invoices in the context of public procurement, which makes it obligatory for all federal government suppliers to send e-invoices.
Failing to obey the mandate can lead to significant penalties, such as:
- Issuing non-compliant invoices may result in financial fines.
- Customers may face challenges recovering VAT if they do not receive accurate e-invoices.
- Invoices that do not comply with the new requirements may result in customers refusing to pay, which will negatively impact your business's cash flow
Best practices for successful e-invoicing adoption for businesses in Belgium
To successfully adopt electronic invoicing, Belgian businesses should consider the following best practices.
1. Register your company on Mercurius
Mercurius is the centralized digital mailroom that enables the integration of systems between senders and recipients. It is equipped with an online portal that is open to all Belgian organizations and provides tracking for senders, recipients, and their service providers.
The platform allows you to receive and handle electronic invoices free of charge, even if you do not yet have a dedicated IT solution.
It's the ideal solution to start your journey of discovering e-invoicing and gathering some information before setting up your own solution.
To get started, complete the following form using your eID (electronic identification). After registering, you will be informed about the next steps and how to use the Mercurius web portal.
2. Invite your economic operators to send you electronic invoices
Next, notify your economic operators that you would prefer to receive invoices electronically. With the help of Mercurius and this flow of incoming invoices, you can acquaint yourself with this new format and identify the potential and critical success aspects of your e-invoicing operation.
3. Launch an e-invoicing project for your organization
When considering the implementation of e-invoicing, it's important to assess the required changes to your IT infrastructure and the level of involvement your business will need throughout the project.
Start by analyzing your existing infrastructure to understand how automating invoice processing can bring both quantitative and qualitative benefits.
Quantitatively, automation can lead to faster processing times, reduced error rates, and lower administrative costs. Qualitatively, it can improve accuracy, enhance supplier relationships, and ensure compliance with regulatory standards.
Next, define a clear implementation strategy for e-invoicing within your organization. This strategy should include the following steps:
- Assembling an e-invoicing project team.
- Leveraging cloud-based e-invoicing facilitating platforms like Storecove.
- The IT solution you adopt must meet your needs and comply with the European PEPPOL framework.
- Integrate with existing accounting and enterprise resource planning (ERP) systems to minimize disruption and allow for a seamless transition to automated invoice processing.
You may also like: Comparative Review of Leading ERP Systems: Which One is Best for Your Business?
4. Put the chosen solutions in place
The project execution phase follows the planning phase. After the solutions are implemented, testing will be necessary to ensure they are correctly connected with the current components. However, more importantly, you will need to instruct your business teams on how to use this new workflow.
Read also: Reselling vs. Building E-Invoicing Solutions: A Strategic Decision for ERP Integration Companies.
Takeaway: Navigate Belgium’s e-invoicing regulation seamlessly with Storecove
The implementation of e-invoicing in Belgium has gradually expanded to business-to-business (B2B), with the mandate planned to be introduced in a single phase on January 1, 2026.
Implementing the mandatory electronic invoicing regulation will streamline business transactions, reduce administrative burdens, reduce costs, and enhance data accuracy.
The best thing you can do now as a business is to prepare for this change. While getting your company set for this change, you can partner with Storecove to help you create the structure you need to correctly send and receive e-invoicing.
We are experts and have helped over 50,000 companies enjoy the benefits of structured document exchange. If you would like to learn more about e-invoicing in Belgium, contact Storecove today!
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