What does Belgium’s mandatory Peppol E-Invoicing mean for foreign companies?

Belgium has introduced the obligation to send and receive structured electronic invoices as of 1 January 2026. If you are not established in Belgium but you do business in Belgium, the question arises whether this change will also affect your company? We looked into it for you.

WHAT IS A “STRUCTURED ELECTRONIC INVOICE”? 

A PDF invoice sent via email is an electronic invoice but does not necessarily qualify as a structured electronic invoice. The structured electronic invoice is a specific type of electronic invoice that enables automated and electronic processing. It is generated in the PEPPOL BIS format and sent via the PEPPOL network. PEPPOL stands for Pan-European Public Procurement Online. Deviations from this format are possible, provided both parties agree. However, in such cases, invoices must still comply with European standards regarding semantics and syntax.

DOES THE E-INVOICING OBLIGATION ALSO APPLY TO FOREIGN ENTREPRENEURS? 

The mandatory structured electronic invoicing between businesses (B2B) is has entered into force on January 1, 2026, and applies when the following three criteria are jointly met:

Who is required to issue? 

The obligation to issue structured electronic invoices generally applies to all companies established in Belgium, with a few exceptions. Foreign companies with a fixed establishment for VAT in Belgium are treated as Belgian VAT-registered taxpayers and must issue structured electronic invoices, provided the other conditions are met.

VAT taxpayers not established in Belgium are not required to issue structured electronic invoices, even if they are VAT-registered in Belgium, whether or not through the appointment of a fiscal representative.

Who must be able to receive? 

The obligation to receive structured electronic invoices generally applies to all companies established in Belgium, with a few exceptions. Foreign companies with a fixed establishment for VAT in Belgium are treated as Belgian VAT-registered taxpayers and must be able to receive structured electronic invoices, provided the other conditions are met.

VAT taxpayers not established in Belgium are not required to receive structured electronic invoices, even if they are VAT-registered in Belgium, whether or not through the appointment of a fiscal representative.

For which transactions? 

Structured electronic invoices are not mandatory for all transactions. Various technical limitations apply. Broadly speaking, the obligation is limited to the local supply of goods and services that take place in Belgium for VAT purposes, are not exempt under Article 44 of the VAT Code, and where the goods are not shipped or transported from Belgium to another EU member state or to a location outside the EU. Additionally, the obligation only applies when Belgium is the competent member state to establish the invoicing rules.

CONCLUSION 

From the combination of the aforementioned criteria, we can conclude that foreign companies without a fixed establishment for VAT in Belgium:

• are not required to issue structured electronic invoices;
• are not required to receive structured electronic invoices

Is your foreign company subject to the obligation to issue and/or receive structured electronic invoices? If so, it is advisable to take the necessary steps.

Would you like more information about this legislation? Our specialists at Van Havermaet will be happy to assist you!