Since 1 January 2026, Belgium has become the first European Union country to make B2B e-invoicing via the Peppol network mandatory for all VAT-registered businesses — with no size threshold and no sector-specific exemption. The tolerance period expired on 31 March 2026. Administrative penalties have been enforceable since 1 April. Nine months after the mandate came into force, approximately 88% of affected businesses are registered on the Peppol network, according to data presented at the Peppol Conference Europe in Brussels in June 2026. The remaining 12%, along with the many businesses that are “superficially compliant” — registered but not actually processing real XML flows — face growing exposure as enforcement intensifies.
This guide sets out the exact legal framework, the technical standard, the role of Peppol Access Points, the implications for the main ERPs used in Belgium, and the concrete steps required for genuine compliance ahead of the 2028 horizon.
Belgium: Europe’s Pioneer in Mandatory B2B E-Invoicing
A Progressive Path Since 2019
Belgium did not start from scratch. Since 2019, Belgian public authorities had already made e-invoicing mandatory for federal public procurement via the Peppol network — what practitioners call the B2G (Business-to-Government) obligation. On 1 March 2024, this requirement was extended to all Belgian public contracts, including regional and local government. This five-year B2G experience provided a unique test bed: it allowed large-scale real-world testing of the Peppol network, helped build an ecosystem of certified service providers, and developed in-house expertise within the Belgian tax administration (SPF Finances — einvoice.belgium.be).
When Belgium extended the obligation to B2B in 2026, it already had a significant head start over its neighbours: an operational Peppol network, more than 475 certified software solutions available on the Belgian market (Peppol Conference Europe 2026), and businesses already familiar with structured invoicing.
Legal Framework: Law of 6 February 2024 and Royal Decree of 14 July 2025
The B2B obligation rests on two founding texts. The Law of 6 February 2024 amended the Belgian VAT Code to introduce the requirement to issue and receive structured electronic invoices in domestic B2B transactions. This law set the effective date as 1 January 2026 for all Belgian VAT-registered businesses (RSM Belgium).
The Royal Decree of 14 July 2025 then specified the practical modalities: the mandatory technical format (Peppol BIS Billing 3.0, compliant with EN 16931), the transmission mechanism (4-corner Peppol network), the schedule of administrative penalties, and the provisions for electronic document archiving (TJC Group).
Together, these two texts give Belgium one of the most precise legal frameworks in Europe for intercompany e-invoicing.
The Obligation Since 1 January 2026: Exact Scope and Penalties
All Businesses, No Size Threshold
Unlike France, which phased its obligation by company turnover, Belgium introduced no size-based phasing. Since 1 January 2026, the rule applies uniformly to all VAT-registered businesses in Belgium: sole traders, micro-enterprises, SMEs, mid-market companies and large corporations alike. Only businesses operating exclusively B2C — those that invoice only private individuals — are exempt from the issuing obligation. However, they remain required to be able to receive structured electronic invoices from their suppliers.
This symmetry of the obligation — covering both issuance AND receipt — is what sets the Belgian model apart from most other European mandates currently in force. In Germany, for example, only the receiving side is mandated for recipients. In Belgium, both directions are legally binding (Vertex Inc.).
Penalty Schedule Since April 2026
The Belgian tax authority (SPF Finances) had provided a three-month tolerance period for businesses demonstrating a genuine compliance effort. That period expired on 31 March 2026. Since 1 April 2026, administrative penalties are fully enforceable:
- €1,500 for the first identified infringement
- €3,000 for a second infringement within three months
- €5,000 for each subsequent infringement
These amounts are calculated per non-compliant invoice, not per company or per fiscal period. For an SME issuing 50 invoices per month without an operational Peppol connection, the financial exposure can quickly amount to tens of thousands of euros under a targeted audit (Xerius).
In addition, an invoice that does not comply with the structured format may be rejected for upstream VAT recovery — a direct financial risk for businesses with high purchase volumes.
The Peppol Network and BIS Billing 3.0: Understanding the Technical Standard
Peppol: A Decentralised 4-Corner Network, Not a Central Platform
A common misconception is to picture Peppol as a central portal where invoices are deposited. The reality is different. Peppol (Pan-European Public Procurement On-Line) is a decentralised 4-corner network: the issuing company sends its invoice to its own Access Point (corner 1), which forwards it to the recipient’s Access Point (corner 2), which routes it to the recipient’s management system (corner 3). The regulatory authority occupies the fourth corner in advanced reporting models. No central intermediary stores the invoices.
The practical implication: to join the Peppol network, your business must be registered in the Peppol directory (the Service Metadata Publisher — SMP) using your Belgian VAT number in the format BE:0208 + your 10-digit number. This registration can be done by your ERP (if it includes a certified Access Point), by a third-party platform, or by your bank — but registration alone does not guarantee that your invoicing flows are actually operational.
UBL 2.1 Format Compliant with EN 16931: What a PDF Cannot Do
Peppol BIS Billing 3.0 is the technical profile required in Belgium. This profile is built on the UBL 2.1 (Universal Business Language) or CII (Cross Industry Invoice) format, both compliant with the European standard EN 16931. This standard defines a common semantic model: how to represent invoice information (amounts, VAT, party identifiers, line items) in a structured, machine-readable format.
A PDF — even one with a digital signature — is not an electronic invoice under Belgian law. A PDF is an image of an invoice; a Peppol invoice is an XML file containing structured data that can be processed directly by the recipient’s accounting system, without re-keying or optical character recognition. The difference is akin to sending a scanned letter versus sending a fully automated form.
Choosing a Peppol Access Point in Belgium
The Belgian market has more than 40 Access Points certified by OpenPeppol. The choice depends primarily on your ERP and your invoice volumes:
- Billit: Belgian platform specialised in B2B invoicing, certified Access Point, with native integrations for the main Belgian ERPs and accounting applications.
- Banqup (Unifiedpost Group): Belgian SME-focused solution with banking integration and management of both inbound and outbound flows via a unified portal (peppolsolutions.eu).
- CodaBox: historically known for Belgian bank codification (CODA), now a certified Peppol Access Point. Widely used by accounting firms, it eases the transition for SMEs that work through a chartered accountant.
- Basware, Pagero, Edicom: international providers suited for multinational groups looking to unify their Peppol infrastructure across multiple European countries.
If your ERP already includes a certified Access Point (Odoo is the most notable example in Belgium), no third-party provider is needed — the Access Point cost is included in your subscription.
ERP Impact: What Your System Must Be Able to Do Natively
Regardless of which solution you choose, your ERP must cover four minimum functional requirements to be genuinely compliant with the Belgian obligation:
- Generation of invoices in UBL 2.1 format compliant with Peppol BIS Billing 3.0 (not an XLS or PDF export).
- Connection to the Peppol network via a certified Access Point, in both sending and receiving directions.
- Automatic receipt and processing of inbound invoices in XML format, with routing to the accounting interface without re-keying.
- Archiving of electronic documents in an unalterable format for at least 7 years, in line with Belgian tax requirements.
Belgian ERPs with Native Peppol Support
Winbooks Connect (Exact Group) and Sage BOB 50 are the two pillars of French-speaking Belgian accounting. Both solutions delivered their Peppol updates ahead of 1 January 2026 and are certified to issue and receive BIS Billing 3.0 invoices without any add-on module. Exact Online (cloud-native, dominant in Flanders) has a structural advantage: regulatory updates are deployed automatically to all customers without requiring any installation. For a detailed comparison of these players nine months after the mandate started, see our Belgian ERP market overview 2026.
Odoo (headquartered in Ramillies, Belgium) deserves special mention: it is the only major generalist ERP to be a certified Peppol Access Point in its own right. The l10n_be_edi_peppol module, included by default in Odoo 17.0 and 18.0, turns Odoo into a Peppol network entry and exit point — no third-party connector, no additional Access Point cost.
French ERPs with a Belgium Module
Cegid XRP Flex and Sage X3 do not include a native Peppol Access Point for Belgium. Compliance requires certified third-party connectors — Banqup, CodaBox, Edicom or Basware — interfaced with the ERP via standard EDI connectors. An integration project typically takes 4 to 8 weeks depending on the complexity of the invoice flows. French groups with Belgian subsidiaries running on these ERPs should verify that the Belgium localisation is activated and that the Peppol connector is deployed: this is not always the case in a standard configuration.
International ERPs: SAP, Dynamics 365, Oracle
SAP S/4HANA covers Belgian Peppol compliance via the Advanced Compliance Reporting (ACR) module. The configuration requires setting the Peppol identifier in the format BE:0208 + VAT number, and correctly isolating Belgian entities in the numbering scheme if the instance is shared with French or Dutch entities. SAP Business One generally connects via a third-party Access Point (Edicom, Tungsten Network, Basware).
Microsoft Dynamics 365 Business Central has included native Peppol support since the 2024 Wave 2 release. In SaaS cloud mode, Microsoft acts as the certified Access Point itself, which simplifies configuration to activating the Belgian localisation module. For configuration details by ERP, our 9-month operational review covers SAP, D365, Odoo, Sage and Cegid cases in detail.
Action Plan: 5 Steps to Genuine Compliance
A business “registered on Peppol” is not necessarily compliant. Here are the five steps that distinguish surface-level compliance from operational compliance.
Step 1 — Verify registration in the Peppol directory. Check directory.peppol.eu and search for your VAT number in the format BE:0208+XXXXXXXXXX. If it does not appear, or if it points to an inactive Access Point, registration must be redone.
Step 2 — Audit your outbound flow. Does your ERP actually generate UBL 2.1 files compliant with the BIS Billing 3.0 schema? Test an invoice on the official Peppol validator (peppol.eu). A valid file passes both the XSD rules and the business rules of the schema. A basic XML with minimum fields is not necessarily valid.
Step 3 — Test your inbound flow. Ask a trusted supplier to send you a test Peppol invoice. Verify that the XML file is received by your ERP (not just in a webmail portal) and that it is automatically routed to your accounting interface. This is where most “false compliances” are exposed.
Step 4 — Address unregistered suppliers. Identify your top 50 suppliers by invoice volume and check their Peppol status. For those not yet registered, document a fallback process — receipt via a transitional portal or monitoring of their compliance progress.
Step 5 — Configure legal archiving. Electronic invoices must be retained for 7 years in an unalterable format. Verify that your document management or archiving solution is configured to guarantee document integrity and that the retention policy aligns with SPF Finances requirements.
2028: Real-Time E-Reporting — The Next Obligation to Prepare For
The 2026 B2B Peppol mandate is only the first step in Belgium’s fiscal digitalisation roadmap. By 1 January 2028, Belgium plans to introduce a near-real-time e-reporting system: VAT data from each B2B transaction will be transmitted simultaneously to the tax authority via a 5-corner Peppol model, replacing the current annual customer listing (Edicom).
Businesses that built a clean Peppol integration in 2025–2026 — with a genuine end-to-end XML flow, not a workaround via a manual portal — will be better positioned to absorb this second wave without a major overhaul. Those that relied on workarounds (PDFs submitted through a portal that generates XML on the back end) will need to rework their infrastructure.
Also worth noting: the enhanced 120% tax deduction on Peppol compliance costs (software, consulting, training) granted by SPF Finances for fiscal years 2024 to 2027 expires on 31 December 2027. Ongoing compliance projects should therefore aim to invoice their costs before that date to benefit from the tax advantage.
To understand what the Belgian experience means for neighbouring countries still waiting on their own mandates, our article on the lessons the Netherlands can draw from the Belgian model outlines the three key takeaways applicable to other national mandates.
Peppol compliance in Belgium has not been optional since 1 April 2026. For businesses that have a Peppol registration but have not validated their end-to-end flow, the window to get in order before enforcement intensifies is narrowing. If your ERP handles Belgian operations through a solution that does not yet include a certified Peppol connector, our analysis of Afas Profit 8 as a Peppol service provider in Belgium illustrates how an external provider can fill that gap without replacing the ERP in place.
To go further in assessing your current setup, download our ERP evaluation grid — 30 criteria across 100 points to benchmark your solution on compliance, Peppol readiness and legal archiving.
