Summary
- B2G mandate: Yes, the federal law on public procurement of 7 April 2019, which transposes Directive 2014/55/EU, obliges public sector administrations to receive and process eInvoices compliant with the European standard EN 16931[1]. Regional mandates have been in place since 2017 (Flanders), 2020 (Brussels), and 2022 (Wallonia).
- B2B and B2C mandates: Business-to-Business (B2B) eInvoicing will become mandatory from 1 January 2026. This means that Belgian VAT-registered businesses will be required to exchange structured eInvoices directly between their systems. Business-to-Consumer (B2C) eInvoicing remains voluntary and is not subject to legal obligation.
- eInvoicing standard: Belgium has adopted the European eInvoicing standard (EN 16931) [2]. All public contracting authorities in Belgium are required to accept and process electronic invoices that comply with the European Standard for eInvoicing for all public procurement contracts above EU Public Procurement thresholds. [3]
- Operating model for B2G eInvoicing: The Mercurius platform serves as the central hub for B2G eInvoicing, fully aligned with the Peppol model. It supports both automated and manual invoice submission and provides tracking services.
- Use of CIUS and Extensions: Belgium uses the Peppol BIS Billing CIUS, which supports cross-sector and cross-border exchanges. No additional national CIUS has been identified as necessary.
- VAT Real-time reporting system: Belgium is preparing to introduce a near real-time VAT reporting system as part of a broader tax reform. The system will eventually replace the annual sales listing.
- Monitoring mechanism: The Mercurius platform includes tracking and tracing capabilities, ensuring compliance and interoperability across public sector entities.
Highlights
Belgium's commitment to eInvoicing is reinforced by the implementation of federal laws and regional mandates, which gradually enforce use of e-Invoicing in public procurement (B2G), and organize the rollout of e-Invoicing in the private sector (B2B). Underlying this regulatory effort, and based on a market-driven philosophy, technical works show that such national rollout of eInvoicing in both the public and private sectors, requires a strong network governance. Belgium opted for the Peppol interoperability model, which provides suitable network governance. Belgium expects that such eInvoicing rollout strategy leads to a break-through moment in the digitalisation of the Belgian Economy and society. Central to this effort is the Mercurius platform, fully integrated with the Peppol interoperability model, acting as the main hub for eInvoicing within the public sector and simplifying the process for both suppliers and public entities.
Legislation
B2G
Belgium has a business-to-government (B2G) eInvoicing mandate. The federal law on public procurement of 7 April 2019 transposes Directive 2014/55/EU, requiring public sector administrations to receive and process eInvoices compliant with the European standard (EN 16931). The Royal Decree of March 9, 2022 further expands this obligation, introducing a phased implementation based on contract value and publication date:
- Contracts equal to or greater than EUR 215,000:
Suppliers must issue eInvoices for tenders published on or after 1 November 2022. - Contracts equal to or greater than EUR 30,000:
Suppliers must issue eInvoices for tenders published on or after 1 May 2023. - Contracts below EUR 30,000:
Suppliers must issue eInvoices for tenders published on or after 1 November 2023. - Contracts below EUR 3,000:
These are exempt from the eInvoicing obligation.
This means that the larger the contract, the earlier the eInvoicing requirement applied. The phased approach allowed suppliers and contracting authorities to gradually adapt to the mandate based on the scale of procurement.
The regional government of Flanders decided in 2016 to make the use of eInvoices in B2G procurement also mandatory for economic operators as of 1 January 2017 for all its regional entities.
Since 1 November 2020, only eInvoices are accepted for all public contracts awarded by the administrations and public organisations of the Brussels-Capital Region.
Since 1 January 2022, eInvoices are the preferred method for B2G transactions in the Wallonia region following the region’s announcements and a guide for the contracting suppliers. Invoices sent via PDF or Word formats are no longer accepted, but invoices that don’t fall under the above-mentioned legal obligation, can still be submitted by post.
Invoices must be submitted via the Peppol network and must include key details such as invoice reference, VAT number, and bank account information.
B2B
Business-to-business (B2B) eInvoicing will become mandatory in Belgium from 1 January 2026 as published in the federal law modifying the vat code of 06.02.2024.
B2C
There is no business-to-consumer (B2C) eInvoicing mandate.
Status on the implementation of the European eInvoicing standard
Belgium has implemented the European standard EN 16931 across all public entities. eInvoices are exchanged using Peppol, a secure and standardized network that allows businesses and public authorities to exchange electronic documents, such as invoices, in a structured and interoperable way.
Operating model for eInvoicing
The seamless exchange of electronic invoices between all public and private sector entities (approximatively 1.200.000 entities) and their automated processing both at the sender- and the receiver-sides, can only be achieved by agreeing on a set of rules and standards between all the systems required to support the diversity of business requirements that such a large-scale implementation involves. Technical works have shown that the Peppol interoperability model provides network governance that, in complement with the market forces, enables such large-scale seamless exchange combined with automation potential. Consequently, Belgium relies on the Peppol network and its strong network governance to achieve eInvoicing generalization in the public and private sectors.
Peppol is the primary format and transmission method in Belgium: no entity can solely decide to derogate to it. Alternative formats and transmission methods can only be used when there is a mutual agreement between parties, and the alternative format can be converted to EN16931. Parties can not force their contracting parties to use an alternative, so the default track via Peppol must always be possible.
More information (including an extensive FAQ) can be found here.
In addition to Peppol, between 2015 and 2020, the Belgian public sector deployed a set of supporting measures to boost adoption of eInvoicing in public procurement and beyond. The most visible one is the Mercurius platform. Conceptually, Mercurius takes the role of the main mailroom for the public sector, thereby (a) relieving invoice senders from the burden of set bilateral connections with all public sector receivers, and (b) supporting public sector entities in their eInvoicing adoption journey by providing them with support. Additionally, Mercurius is equipped with a web portal that is accessible to all Belgian organizations, and provides track and trace services to senders, receivers and their service providers. The portal also supports the manual submission of invoices, to give economic operators more freedom in their own eInvoicing adoption journey.
Mercurius is fully and exclusively aligned with the Peppol, standardised interoperability model and its resulting open ecosystem.
Mercurius also provides various services to public sector entities, to assist them in their eInvoicing adoption journey. It also positively affects the consistency of the public sector entities in the domain of e-Invoicing, thereby making their suppliers life easier.
As time goes by and new use cases arise, the Mercurius platform also supports outbound invoicing (G2B) and two-ways ordering.
To reach consensus with the infrastructure implementation, the Belgian government relied on Fédération des Enterprises de Belgique (FEB) to facilitate the organisation of an expert group including different types of eInvoicing stakeholders. This organisation brings around the table representatives of all stakeholders with an interest in eInvoicing (companies, authorities, solution providers, accounting federation, etc.). It is tasked with identifying concrete solutions to the problems faced by companies in implementing eInvoicing and provide appropriate recommendations.
Alongside Mercurius, Belgium developed the Hermes platform which has been introduced to support entities that are not yet equipped to receive structured eInvoices. Hermes serves as a temporary solution that converts structured eInvoices into readable formats (e.g., PDF) for recipients who lack the necessary tools. This ensures inclusiveness and encourages broader adoption of eInvoicing. Hermes also includes a web portal with tracking features. Hermes is designed to be phased out as digital maturity increases.
Use of Core Invoicing Usage Specifications (CIUS) at national level
Belgium uses a predefined format called Peppol BIS BILLING 3.0 to structure its electronic invoices. This format follows the European standard (EN 16931) and ensures that invoices can be exchanged easily between different systems and countries.
There is no ad hoc or national CIUS version. To date, no need for such an additional specification has been identified in the context of public procurement. Belgian public sector entities using Mercurius also receive the Peppol Document type format that implements the European Norm using the UN/CEFACT syntax. To date (15-05-2025), no such document has been received yet.
VAT Real-time reporting system
Belgium intends to widen the obligation of eInvoicing, with an eReporting layer, by 2028. The planned reform concerns the introduction of an electronic VAT reporting system. This electronic VAT reporting system will be near real-time (Continuous Transactions Control). The system will replace in time the existing annual sales listing. The system will again leverage the interoperability specifications from the Peppol framework, limiting the impact on businesses already connected for eInvoicing purposes.
Monitoring mechanism
Belgium relies on the Peppol reporting mechanism to monitor traffic increase and users activation. Figures are published on Peppol | BOSA.
Next steps
As from 1 January 2026, all Belgian enterprises liable to VAT will have to use structured eInvoices in their transactions with each other. These invoices are exchanged directly between the two enterprises' software systems. Sending a PDF invoice by e-mail or via a platform will no longer be enough. The scope of mandatory B2B eInvoicing in Belgium requires consideration of the supplier, customer, and transaction involved. Entities must conduct a screening to determine if they are obligated to implement eInvoicing.
Suppliers, defined as issuers of eInvoices, include all Belgian VAT taxpayers, such as taxable entities in Belgium, Belgian permanent establishments of foreign entities, members of Belgian VAT groups, and taxable Belgian entities with special VAT schemes in agriculture. Excluded suppliers are foreign entities solely registered for VAT in Belgium, Belgian entities conducting certain VAT-exempt activities, bankrupt entities, and those under a special flat-rate scheme, which will be abolished in 2028. Customers must be able to receive and process eInvoices; this applies to taxable entities providing their Belgian VAT number for local transactions. Exempt from this requirement are certain VAT-exempt entities and foreign taxpayers with a Belgian VAT number, without permanent establishment. eInvoicing applies to all local B2B VAT transactions in Belgium unless exempt under article 44 of the Belgian VAT Code, including supplies under local reverse charge. Transactions like intra-community supplies and services taxed in another EU country are not included in the eInvoicing scope.
eReporting is planned for 2028 (see above).
Belgium will implement the VIDA directive (Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age) and ensure alignment with eInvoicing and eReporting obligations as foreseen in the Directive.
[1] The European Standard on EU law sets minimum harmonised rules for tenders whose monetary value exceeds a certain amount and which are presumed to be of cross-border interest. More information can be found via: https://single-market-economy.ec.europa.eu/single-market/public-procurement/legal-rules-and-implementation/thresholds_en [2] The European Standard on eInvoicing (EN 16931) defines a common format and data model for electronic invoices, ensuring they are structured, machine-readable, and compatible across EU systems. [3] Ibid.2 [4] Ibid.1
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