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Three months of grace, then enforcement.
Belgium e-invoicing penalties can be imposed since 1 April 2026. From 1 January 2026, VAT-registered businesses established in Belgium must exchange structured e-invoices with each other, in practice over the Peppol network. By December 2025 more than half a million businesses had joined, and the Belgian tax authority (FPS Finance) gave the rest three months without fines, provided they had started in time.
On 7 April 2026 it confirmed that this grace period ended on 31 March. There is no general postponement. Below: how a fine builds up, whether a supplier outside Belgium is in scope, who sends and who only receives, and what getting compliant costs.
- First finding, May 20261,500
- Second, September 2026: more than three months later3,000
- Third, January 2027, and every one after5,000
- Together, if nothing changes in between9,500
Royal Decree of 8 July 2025. A second or third fine counts as a repeat only if it is established at least three months after the previous fined offence.
How a fine builds up
The fine is set in the Royal Decree of 8 July 2025 and hits a business that lacks the technical means to send or receive a structured e-invoice. It is not proportional: the amount does not depend on how many invoices went wrong, only on how often the tax authority establishes the offence. A second or third fine counts as a repeat only when the new offence is established at least three months after the previous fined one. Those three months are your window to fix things. The ordinary VAT fines for incorrect invoices keep applying on top.
In exceptional cases, such as a technical problem you could not solve yourself, the authority can waive a fine. That never happens automatically: you submit your case through the contact form on einvoice.belgium.be and it is looked at on its own merits.
Suppliers outside Belgium: in or out?
A business without a fixed establishment in Belgium is not obliged to send Peppol invoices, even when it holds a Belgian VAT number. The rules on what counts as a fixed establishment are complex, so the Belgian authority asks non-established suppliers to tell their customers themselves. A German web shop selling to Belgian companies, or a Dutch SaaS with Belgian clients, is in that position.
Two cases are different. A foreign group with a Belgian branch that is a fixed establishment must send from that branch. And a Belgian company acting as the representative of a non-established business is in scope under its own Belgian number, unless it acts as an individually or globally liable representative with a specific number starting BE0796.5 or BE0796.6.
Out of scope does not mean out of the conversation. Your Belgian customers must be able to receive, and many will ask you to send over Peppol because it saves them retyping. The short answer per case is in is Peppol mandatory in Belgium.
Who sends and who only receives
| Your situation | Must send | Must receive |
|---|---|---|
| VAT-registered business established in Belgium, invoicing Belgian businesses | Yes | Yes |
| Small Belgian business under the VAT exemption scheme, up to EUR 25,000 turnover | Yes, see Peppol for small businesses | Yes |
| Belgian flat-rate taxpayer, a scheme that ends by 1 January 2028 | No | Yes |
| Belgian non-profit with a VAT number | Follows its VAT status, see Peppol for non-profits | Follows its VAT status |
| Sells only to consumers, buys from Belgian businesses | Not for consumer invoices | Yes |
| Foreign business with a Belgian VAT number but no establishment in Belgium | No | No |
| Foreign business with a fixed establishment in Belgium | Yes, for supplies from that establishment | Yes |
Without a VAT number at all, read Peppol without a VAT number. The full picture of the mandate, in plain English, is in our guide to e-invoicing in Belgium.
Where invoices still get stuck
- An invoice from Word or ExcelA PDF is not a structured e-invoice. It has to leave as a UBL file over Peppol.
- A web shop that invoices itselfB2B orders from a Belgian entity's shop must go out through a Peppol provider, not as an email attachment.
- Job sheets in a system of your ownIf you invoice from a planning or job tool, it needs a connection, or someone retypes everything.
- Forgetting to receiveEven a business that rarely invoices must be able to receive e-invoices from suppliers.
Joining the network from another country
Peppol is an international network, not a Belgian portal. You join through a certified access point, which can sit in any country, and your invoice travels as a UBL invoice that lands in your customer's bookkeeping as data. Before you start, check whether your Belgian customers are listed with our Peppol check. How a company registers is in Peppol registration, and which tools send and receive is in which software do you need for Peppol.
The trouble usually sits outside the accounting package: invoices that come out of a planning tool, a job-sheet app, a shop or a spreadsheet. A connection to an access point puts those invoices on the network with VAT per line and a Belgian structured communication for the payment. That is what Peppol invoicing software built around your own data does, and what a work order app that invoices straight after the job does. Incoming invoices can be read the same way with invoice automation.
What compliance costs inside Belgium
For a Belgian business, getting compliant costs less than one fine. One public price list as an example: at Billit, one of the providers offering Peppol, a plan for up to 25 documents a month costs EUR 7.50 a month billed monthly, network access included. Small Belgian SMEs and self-employed people deduct such a subscription at 120 percent in the taxable periods 2024 to 2027.
| Item | Amount |
|---|---|
| Subscription up to 25 documents, 12 x EUR 7.50 | EUR 90.00 a year |
| The same plan billed yearly, 12 x EUR 6.90 | EUR 82.80 a year |
| Deductible at 120 percent, on EUR 90 | EUR 108.00 |
| Extra deduction on top of the normal cost | EUR 18.00 |
A first fine equals almost seventeen years of that subscription. The deduction covers invoicing subscriptions and advice to meet the mandate; a surcharge on an existing package counts only when it is invoiced separately. Since 1 January 2025 a digital investment can also get a 20 percent investment deduction.
When the customer cannot receive yet
If a Belgian customer cannot technically receive, you may send a PDF or paper invoice. The customer remains obliged to be able to receive, so the risk of a fine sits with them. Self-billing, where the customer issues the invoice in the supplier's name, had its own grace period until 30 June 2026. That is over too.
After the fines: e-reporting and ViDA
On 18 July 2026 the Belgian government approved a draft law under which supplier and customer report invoice data to the tax authority almost in real time, replacing the yearly customer listing. It aims for 2028 and is not law yet; read Belgian e-reporting in 2028. At EU level, the VAT in the Digital Age package (ViDA) brings digital reporting with e-invoices for cross-border B2B from 1 July 2030. Everything else that changes next year is in new EU rules for 2027.