From real estate managers to restaurant owners — here’s how the 2026 Peppol obligation impacts different scenarios.
A new mandate, a lot of questions
With Belgium’s e-invoicing mandate taking effect on January 1, 2026, businesses of all sizes are questioning what this means for their daily operations. The rule is clear: any business with a KBO number must be able to receive structured e-invoices via Peppol. However, when it comes to everyday situations — such as issuing a fee as a building manager, dining out for business purposes, or purchasing materials from a local store — things can become unclear.
The confusion around when Peppol applies
There is increasing uncertainty about when Peppol is required and when it is not. Many business owners fear they will have to revamp every part of their invoicing process, even for simple, quick transactions. This results in hesitation — and potentially, non-compliance later on.
What happens if you’re not ready?
Failing to comply with the mandate by 2026 may result in rejected invoices, regulatory challenges, and increased administrative costs. On the other hand, complicating the requirements could lead to wasted time and unnecessary system modifications.
Let’s clarify with three examples:
1. Invoicing as a property manager to a VME
A property manager issues a yearly fee to the association of co-owners (VME) for their services. While they pay the invoice themselves, the recipient is still the VME — an entity with a KBO number and is established in Belgium.
What this means:
If the VME has a KBO number (which most do), the invoice must be sent via Peppol. Even if the payment is processed internally, the invoice flow still counts as business-to-business.
If the VME has a KBO number but is not established in Belgium, you aren’t required to use Peppol.
Tip: Ensure your syndicus software or invoicing system is Peppol-ready by 2026.
2. Business lunches and restaurant invoices
An entrepreneur takes a client to lunch and pays immediately. They ask for an invoice to expense the meal through their company.
What this means:
This is a point-of-sale transaction because payment occurs immediately and the invoice is issued on-site. The restaurant is not obligated to send the invoice via Peppol, though some might offer it optionally.
Tip: No Peppol needed here. Standard invoices are still valid for these B2C-style purchases.
3. Buying tools or supplies from a local shop
A small construction company purchases tools from a local store and pays at checkout. It requests an invoice for its business.
What this means:
As with the restaurant scenario, this is an immediate payment situation. A Peppol invoice is generally not required unless the transaction includes delayed payment terms.
Tip: Retailers are not currently required to send Peppol invoices for over-the-counter payments, but this may evolve in the future.
Focus on what matters: B2B with deferred payment
The key takeaway is this: focus your Peppol preparation on business-to-business invoices with delayed payment terms. These are the transactions that fall squarely under the e-invoicing mandate. For immediate payments or invoices to private individuals, Peppol is typically not required.
What should you do next?
Start preparing today by mapping out:
- Who you invoice
- How those invoices are paid (immediate or deferred)
- Whether the recipients have a KBO number
- Whether your systems can send and receive Peppol e-invoices
If you’re unsure where to start, contact us for a short meeting. Together, we’ll map your situation and guide you toward compliance. Or download the Peppol datasheet below.
Peppol: what is it and when it’s mandatory
