The VAT number decides, not the legal form
Belgium's e-invoicing duty is a VAT rule: it applies to invoices between two businesses established in Belgium that are both VAT-liable. Whether you are a company, a sole trader, a vzw or an international non-profit (AISBL), the legal form plays no role. The general rule is on is Peppol mandatory in Belgium.
Most small associations have no VAT number. A football club collecting membership fees and running a yearly quiz invoices nothing with VAT and is out of scope in both directions: a supplier may send it a PDF or paper invoice as before. Many international associations in Brussels are in the same position, as long as they make no taxed supplies. How it works for anyone without a VAT number, including exempt professions, is in do you need Peppol without a VAT number. A non-profit under the small business exemption follows the rule for small businesses: no VAT on the invoice, still over Peppol. A foreign non-profit without an establishment in Belgium is out, even with a Belgian VAT number.
Four associations, four answers
The legal form does not count. The VAT number and the type of work do.
Where it matters for a mixed non-profit
Many non-profits are partly VAT-liable: for the bar in the clubhouse, sponsorship packages for companies or tickets to an event. For those taxed invoices to Belgian businesses with a VAT number the duty applies, and the association must also be able to receive. The Ministry of Finance has not written separate guidance for mixed non-profits, but the general rule leaves little room. Without the means, a non-profit risks the same fines as a company: 1,500 euro, then 3,000 and 5,000 euro, since the tolerance ended in April; see the news on the e-invoicing penalties. Per kind of invoice:
| Invoice from your association | Over Peppol? | Why |
|---|---|---|
| Membership fee | no | not an invoice to a VAT-liable business |
| Sponsorship package for a company | yes, if you are VAT-liable for it | a taxed service to a business |
| Room hire with VAT to a company | yes | a taxed letting to a business |
| Ticket to a private person | no | no business on the other side |
| Stand or tickets for a company | yes, with a VAT number | a taxed service to a business |
| Invoice to a municipality for a contract from 3,000 euro | yes, since 1 March 2024 | a separate rule for public contracts |
| Grant application | no | not an invoice |
Which kinds of packages exist is in which software for Peppol; how to get registered in the guide to Peppol registration, and the wider picture in e-invoicing in Belgium. Whether your association already has an address shows in the Peppol check. Put a Belgian structured communication on each sponsor invoice so the payment matches by itself, and send sponsors a proposal with VAT per line first, as in our quote template. Raising awareness on a small budget? Google Ad Grants is worth a look: see is Google Ads free.
Who is responsible in the association?
The board is, even if a volunteer makes the invoices. Record who manages the Peppol address and who follows up incoming invoices, so it does not leave with the treasurer.
