Regulatory updates - Belgium

In early May, the Belgian authorities updated the e-invoicing FAQ. Below are the key takeaways:

Peppol Delays: Delays in Peppol invoice delivery are now formally recognized. If the delivery of an invoice takes more than one working day, it should be investigated by the software supplier.

Reverse charge: If an invoice lacks the specific Article 20 §3 wording, it should not be automatically rejected, provided the terms "reverse charging of VAT" or "reverse charge" appear within the document. The mandatory details may be referenced in an unstructured or additional information field.

Wrong recipient - incoming invoice: If an invoice is received that was not intended for the recipient, it must not be booked and should be rejected via Peppol using invoice response code "RE." Software must support this electronic rejection mechanism, as it constitutes the official channel and serves as the formal audit trail in the event of a dispute.

Wrong recipient - outgoing invoice: If VAT is chargeable, an invoice sent to the wrong recipient may not simply be deleted from the system, it must be registered and included in the periodic VAT return. A credit note must be issued to correct the error, referencing the original Peppol invoice ID to ensure a complete and compliant audit trail.

Self-billing: The FAQ clarifies that the supplier or service provider must register on Peppol, as they are the party receiving the invoices. A prior agreement between the parties is still required, as is acceptance of each self-billing invoice or credit note.

Obligation Scope

Since January 1, 2026, all Belgian VAT-registered businesses are required to exchange structured electronic invoices. This includes businesses operating under the small business VAT exemption scheme, which are in principle equally subject to this obligation.

The Belgian tax authorities clarify that a business which only invoices private individuals, but purchases goods or services from a Belgian supplier, is still required to comply, as it must be able to receive electronic invoices from that supplier.

Exceptions and Special Cases

The general tolerance period that applied during the first three months of 2026 has ended however two exceptions remain:

• Self-billing: If your software provider has not yet implemented the self-billing functionality, no fine will be imposed until June 30, 2026.
• Exceptional technical issues: On a case-by-case basis, the tax authorities may decide not to impose a fine where genuine technical difficulties can be demonstrated. This is not automatic and requires individual review.

If you believe your situation warrants a specific review, you can submit your case through the official contact form.

The emptying of the Hermes SMP between these hours will render Hermes unavailable for new traffic.

These interruptions come ahead of the expected timeline of full decommission, which was originally announced to be December 31, 2025.