E-invoicing Mandatory from 2026: The Countdown Has Begun

On July 14, 2025, the Royal Decree of July 8, 2025 was published in the Belgian Official Gazette, officially confirming that, as of January 1, 2026, all VAT-registered businesses will be required to send and receive structured electronic invoices.

This marks a significant step in the digital transformation of business and administrative processes.

What the Law Says

From January 1, 2026, every VAT-liable entity in Belgium must have the technical means to:

• issue structured electronic invoices, and
• receive structured electronic invoices.

It is important to note that sending invoices in PDF format by email will no longer be compliant. Only structured invoices, transmitted through the specified network (as defined in the decree, such as Peppol), will meet the legal requirements.

Penalties for Non-Compliance

The Royal Decree introduces a progressive penalty system, similar to the one applied in 2009 for mandatory cash register systems in the hospitality sector:

• First offense from January 1, 2026: €1,500 fine
• Second offense, if not corrected within 3 months: €3,000 fine
• Third and subsequent offenses, after another 3-month period: €5,000 per offense

Easy Remote Enforcement

Unlike previous requirements involving physical infrastructure, this system requires no on-site inspection. Authorities can simply compare the public list of registered e-invoicing users with the national registry of VAT-registered businesses. This makes identifying non-compliant entities quick and automatic.

Concrete Examples

• Example 1: A service provider still sends invoices in PDF format via email and has no infrastructure for structured invoicing. This business is immediately at risk of fines starting in January 2026.
• Example 2: A retailer receives supplier invoices on paper or in PDF and has no solution in place to receive structured invoices. This is also a breach of the new law.
• Example 3: A company has updated its internal systems but failed to register on the official invoicing network. Legally, it is still non-compliant.

The Crucial Role of the Accountant

During this transition, the accountant or tax advisor remains a key figure. They can:

• assess the business’s current situation,
• assist in selecting an appropriate solution,
• ensure compliance with legal obligations, and
• help the business prepare for future digital developments.

With many companies still unprepared, waiting until December is a risky bet.

Don’t wait until the last minute. While this is a legal requirement, it’s also an opportunity to modernize your administrative processes. Rely on your accountant to guide you through it successfully.