FAQ for your finance department

FAQ for your finance department

Peppol and the new legal obligations in Belgium

What is Peppol exactly?

Peppol (Pan-European Public Procurement Online) is an international and secure network for the electronic exchange of business documents, such as invoices. Instead of a PDF or paper invoice, invoices are sent via Peppol as structured electronic data. This allows them to be processed automatically in the recipient's accounting software, without manual data entry.

Is a PDF invoice via email still allowed? 

No. From January 1, 2026, a PDF invoice via email will no longer suffice for Belgian B2B transactions. A PDF is considered an unstructured document and does not meet the legal requirements for electronic invoicing. Only structured e-invoices, sent via a compliant network like Peppol, will be permitted.

From when are you required to work with Peppol?

From January 1, 2026, structured electronic invoicing is mandatory for all B2B invoicing between Belgian VAT-liable companies. Every invoice issued from January 1, 2026, must be sent electronically. The invoice date may still be in 2025, and the invoice may relate to past services; the moment of sending is the determining factor.

VAT-registered taxpayers not established in Belgium and without a permanent establishment, even if they are identified for VAT purposes in Belgium, are not subject to the obligation. The legislation is still being amended on this point.

To which companies does this obligation apply?

The obligation applies to all Belgian VAT-liable companies that invoice other Belgian VAT-liable companies. This includes:

  • Sole proprietorships (eenmanszaken)
  • SMEs (KMO’s)
  • Liberal professions (vrije beroepen)
  • Large enterprises

There are no exceptions based on revenue, sector, or company form.

Does the obligation also apply to B2C invoicing?

No. The legal obligation applies only to B2B invoicing between Belgian companies. Invoices sent to:

  • Private individuals (B2C)
  • Foreign clients
  • Companies without a Belgian VAT number

...fall outside this obligation.

Do I have to use Peppol, or can I choose another system?

The law mandates the use of structured electronic invoices but does not explicitly prescribe Peppol. However, in practice, Peppol is the standard solution because it is:

  • Legally compliant
  • Widely supported
  • Secure and reliable
  • Compatible with most accounting software packages

Alternative solutions are only possible if they fully meet all legal and technical requirements and are accepted by both parties.

What if my client is not yet ready for Peppol?

From January 1, 2026, the recipient is also required to be able to receive electronic invoices. Therefore, a client cannot use the lack of a Peppol setup as an excuse to continue receiving PDF or paper invoices. Non-compliant invoices may legally be refused.

Are there sanctions if I do not invoice via Peppol?

Yes. Fines for non-compliance with the Peppol obligation are:

  • €1,500 for the first violation
  • €3,000 for the second violation
  • €5,000 for the third and every subsequent violation

Important conditions:

  • Non-proportional: These fines are imposed per violation, regardless of the invoice value.
  • Grace period between fines: There is a 3-month grace period between two violations. Only when a subsequent violation is established more than three months after the previous one does it count as a "subsequent violation" for the higher fine.
  • Immediate action: The tax authorities can impose sanctions immediately without issuing a warning first.
  • Scope: The fines relate to the lack of technical means to send and receive e-invoices via Peppol or an equivalent system.

Existing invoicing fines remain in force:

  • In addition to these specific Peppol fines, traditional VAT sanctions for invoicing errors (such as not issuing an invoice on time or missing data) remain applicable.
  • Transition Period: The government provides a tolerance period of three months following the entry into force of the obligation on January 1, 2026.
  • During this transition period, the tax authorities will, in principle, not impose immediate sanctions, provided that companies can demonstrate they have made efforts to bring their invoicing processes into compliance.

What are the benefits of Peppol for my company?

Besides the legal obligation, Peppol offers significant operational benefits:

  • Less manual administration
  • Fewer processing errors
  • Faster and more correct payments
  • Automatic processing in accounting software
  • Lower administrative costs in the long term

Peppol is therefore not just an obligation, but also an efficiency boost towards digital business operations.