Regulatory updates - Belgium

On July 18, the Council of Ministers approved a pre-draft law introducing dual e-reporting from 2028. The reform builds on the e-invoicing obligation for domestic B2B transactions already in force since January 1, 2026, adding a requirement for mandatory invoice data to be transmitted to tax administration in near real time.

This reporting duty is designed as a dual obligation, with the supplier reporting the sale side and the customer the purchase side of the transaction. The government presents this bilateral approach as a way to improve compliance through more digitized and reliable data flows, while also giving tax authorities faster, more detailed information that strengthens risk-based controls.

As a counterbalance to this new obligation, the draft law abolishes the annual customer listing for businesses subject to the new e-reporting duty, offering a measure of administrative simplification alongside the added reporting requirement.

The pre-draft law has now been submitted for review to the Data Protection Authority and the Council of State before it can progress further through the legislative process.

FPS BOSA has announced that the Belgian Peppol Authority will be transferred to FPS Finance as of 2027. The Belgian Peppol Authority was originally established by FPS BOSA at the end of 2015 and has since played a central role in the Belgian e-invoicing landscape.

The transition is driven by the introduction of e-reporting, which requires specific tax expertise that falls more naturally within FPS Finance's remit. The move aims to ensure greater consistency, clearer responsibilities, and more effective decision making as Belgium's e-invoicing and e-reporting framework continues to evolve. FPS BOSA and FPS Finance are already working together to ensure the transfer is structured, legally compliant, and operationally stable.

At this stage, no action is required. Further details on the practical arrangements and timeline will be shared in due course through the usual communication channels, including the Peppol Service Provider Forum, Business Expert Group meetings, and the websites of both FPS BOSA and FPS Finance.

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.