Belgium clarifies its 2026 B2B e-invoicing obligations
Belgium has published a new draft law that refines the 2026 B2B e-invoicing mandate. The text clarifies scope and exceptions, aligns Belgian legislation with the EU VAT in the Digital Age Directive, and confirms that the 1 January 2026 start date remains unchanged.
This draft law follows a series of earlier updates issued throughout 2024 and 2025. These included guidance on the national rollout, the planned closure of the Hermes platform, and the introduction of a conditional grace period. For a full overview of previous steps in this transition, see our earlier articles on Belgium’s grace period, new administrative guidance for the mandate, the closure of Hermes and the 2025 e-invoicing decree.
Belgium has now taken another step in refining its upcoming B2B e-invoicing framework. On 3 December 2025, the government published a new draft law that introduces targeted changes to the 2026 mandate. The objective is to bring national rules in line with the EU VAT in the Digital Age Directive and to provide additional clarity for businesses preparing for the go live.
Why this draft law matters
The new document clarifies several elements that organisations raised after the publication of the 2025 decree and the administrative guidance issued earlier this year. In particular, companies sought more certainty around boundary cases, exemptions and the interaction between Belgian rules and upcoming EU requirements.
These clarifications help finance, tax and IT teams determine whether the mandate applies, what format to use, and how to prepare for a structured, EN 16931 compliant workflow. They build on existing insights already described in our earlier guidance on Belgium’s 2026 e-invoicing rules.
Key clarifications
The draft legislation provides four important updates for companies assessing their obligations.
1. Alignment with the EU VAT in the Digital Age Directive
The text adapts Belgian rules to ensure consistency with upcoming EU requirements for structured invoicing and real time VAT reporting. This alignment supports a smoother long term transition and reduces the risk that companies will need to adjust their invoicing processes again once EU rules progress.
2. Non established taxpayers are formally excluded
Businesses that are not established in Belgium but hold a Belgian VAT number fall outside the mandate under the current proposal. This provides certainty for international groups and aligns with earlier clarifications included in the 2025 decree.
3. Waiver when the customer cannot receive structured e-invoices
The draft law introduces a practical waiver. If a recipient is technically unable to receive a structured e-invoice, the supplier may issue a regular invoice instead. This can be a classic electronic invoice, for example a PDF, or a paper invoice.
The waiver only applies when the inability is genuine and demonstrable. It should not be treated as a general excuse to delay e-invoicing projects. For most B2B relationships, structured e-invoicing remains the default approach.
4. Go live date remains 1 January 2026
The proposal does not introduce additional grace periods or phased rollouts. The 1 January 2026 go live date remains in place. Companies should therefore continue to plan for full compliance from the start of 2026.
What companies should do now
Organisations operating in Belgium should review their invoicing processes, ERP systems and partner capabilities in light of these clarifications. The formal exclusion of non established VAT holders helps reduce uncertainty for international groups. The waiver mechanism gives suppliers a fallback option where customers cannot yet receive structured e-invoices.
At the same time, the direction is clear. Structured, EN 16931 compliant e-invoicing is becoming standard. Finance and IT teams should ensure that their platforms are prepared to send and receive structured invoices through Peppol or another accepted channel and that master data, validation and archive processes are aligned with the new rules.
The full draft text is available for consultation through the Belgian Parliament website:
Full text of the Belgian draft law on the 2026 B2B e-invoicing mandate
Key takeaways
Changes companies need to implement based on this draft law include:
- Confirm whether they fall inside or outside the scope, especially for non established entities with a Belgian VAT number.
- Prepare to issue and receive structured e-invoices as the default for domestic B2B transactions from 1 January 2026.
- Define a clear process for handling cases where customers cannot yet receive structured e-invoices and document when the waiver applies.
- Align internal compliance, tax and IT plans with the VAT in the Digital Age roadmap to avoid duplicate work in the coming years.
Finance and tax managers may also want to review the draft law together with earlier updates for a complete overview of Belgium’s transition path. Relevant sources include our articles on the 2025 decree and the administrative guidance.
