On 1 January 2026, Belgium became the first country in the European Union to mandate B2B e-invoicing via the Peppol network for all VAT-registered businesses. Nine months in, the first adoption figures are in. The headline numbers look impressive — over two million Peppol registrations according to OpenPeppol — but the operational reality is more nuanced: being registered on the network is not the same as being genuinely compliant.
This article takes stock at the mid-year mark: real adoption rates, the most common field errors encountered by SMEs and mid-market companies, the state of Peppol support across leading ERP platforms, and what Belgian businesses should expect in 2027 and beyond.
Recap: What Came into Force on 1 January 2026
Scope of the Obligation
Since 1 January 2026, all VAT-registered businesses in Belgium — sole traders, SMEs, mid-market companies, large enterprises, and liberal professions — are legally required to send and receive their domestic B2B invoices in a structured format via the Peppol network. The required format is Peppol BIS Billing 3.0, compliant with the European standard EN 16931, transmitted by software-to-software exchange between certified Access Points.
The obligation covers both directions of the flow: a law firm that invoices only consumers (B2C) is still required to be able to receive structured invoices from its suppliers.
The Sanctions Timeline
The rollout followed a phased schedule. A three-month grace period was granted by the Belgian Federal Finance Service (SPF Finances) for laggards who demonstrated a genuine compliance effort. Since 1 April 2026, penalties are fully enforceable: €1,500 for a first offence, €3,000 for the second, and €5,000 from the third onward. These amounts apply per non-compliant invoice — not per company or per quarter.
Key Figures at 9 Months: Where Does Adoption Stand?
Record Registration Rates — With One Important Caveat
Peppol statistics make Belgium a global outlier. By 30 January 2026, Belgium had already become the first country worldwide to cross the million-registrant mark on the Peppol directory. By June 2026, OpenPeppol counted 2,148,564 registered endpoints for Belgium — representing 47% of the 4.4 million active participants across the entire global network. France, the second-largest country, had around 890,000 participants.
These impressive numbers come with an important technical caveat. A single Belgian company can appear twice in the directory: once under its KBO/BCE enterprise number, and once under its VAT number. This double-counting — a byproduct of how platforms handle registration conventions — mechanically inflates the totals. In terms of distinct businesses that have actually joined the network, the real adoption rate stood at 88% of in-scope companies as of early June 2026, according to figures presented at the Peppol Conference Europe held in Brussels in June 2026.
Adoption Driven by Platforms, Not Always by ERPs
Three factors explain the speed of Belgian registration. First, banks and accounting platforms (CodaBox, Billit, Banqup) enrolled their entire client portfolios in bulk — often without any direct action from the businesses themselves. Second, 475 Peppol-certified software solutions are available on the Belgian market (Peppol Conference Europe 2026), ensuring broad sector coverage. Third, the government communicated early and clearly on penalties.
The flip side: being enrolled via your bank does not mean your ERP is actually sending and receiving structured invoices. That is where field errors begin.
The 5 Most Common Errors Found in Belgian Mid-Market Companies
Error 1: Peppol Registration Without ERP Configuration
The most widespread failure. The business has a Peppol ID (registered by its bank or Access Point), but the ERP is still generating PDFs. Incoming flows arriving as XML via the Access Point are not routed into the ERP and land in a portal that nobody monitors.
Fix: verify that your Belgian VAT number (format BE:0208 + number) is correctly linked to your Access Point and that your ERP is configured to send and receive via that channel. A send-and-receive test with a trusted supplier partner is enough to validate the end-to-end flow.
Error 2: “False Compliance” — PDFs Renamed as XML
Several vendors offer solutions that mechanically convert a PDF to XML. The resulting XML file contains minimal data but fails Peppol BIS Billing 3.0 schema validation rules. These invoices are technically transmitted over Peppol but rejected by the recipient, or accepted with incomplete data that cannot be used in automated accounting.
Fix: require your software vendor or integration partner to provide an EN 16931 compliance certificate, and run a validation test using the official Peppol validator (https://www.peppol.eu/). The only reliable indicator is validation against the XSD schema and Peppol business rules.
Error 3: Credit Notes Incorrectly Configured
Peppol credit notes follow different rules from standard invoices — different XML format, additional mandatory fields including the original invoice identifier and the reason for the credit. Many ERPs were configured for outbound sales invoices but not for the corresponding credit notes. The result: credit notes transmitted in an invalid format, automatically rejected, creating accounting disputes between suppliers and customers.
Fix: explicitly test the credit note flow before going live. The credit note is the most commonly overlooked test case during Peppol acceptance testing.
Error 4: No Fallback Plan for Unregistered Suppliers
Roughly 12% of in-scope businesses were still not registered on the Peppol network at mid-2026. For mid-market companies with dozens or hundreds of active suppliers, a supplier not in the network blocks automated invoice receipt. Without a documented fallback — a transitional structured email, a submission portal, or a supplier outreach process — finance teams revert to manual processing for these cases, wiping out much of the expected productivity gain.
Fix: before your Peppol rollout, map your top 50 suppliers by invoice volume and check their registration status on the OpenPeppol directory. Build an automated follow-up process for the unregistered ones.
Error 5: Non-Compliant Attachments
Delivery notes, service reports, or terms and conditions attached to invoices cannot be transmitted in a free format via Peppol BIS 3.0. The standard only allows attachments in PDF/A or PNG, with size constraints. Companies accustomed to attaching ZIP archives or Word documents have seen their invoices rejected or incorrectly processed at the recipient’s end.
Fix: reduce attachments to the bare minimum (delivery note in PDF/A), or route supplementary documents through an external document portal whose URL is referenced in the invoice body.
How Leading ERP Platforms Handle Peppol in Belgium
SAP S/4HANA and SAP Business One
SAP S/4HANA covers Peppol BE compliance via the Advanced Compliance Reporting (ACR) module. Configuration requires setting the Peppol ID in BE:0208 format followed by the 10-digit Belgian VAT number. For groups running Belgian subsidiaries on shared S/4HANA instances, verify that Belgian company code numbering schemes are correctly isolated — a mapping error can route French or Dutch invoices into the Belgian Peppol channel.
For SAP Business One, compliance typically runs through a certified connector from providers such as Edicom, Tungsten Network, or Basware, acting as the Peppol Access Point.
Microsoft Dynamics 365 Business Central
Business Central has included native Peppol support since the 2024 Wave 2 release. The 2026 Wave 1 update (April 2026) adds purchase invoice previews in Peppol format before accounting registration, making it easier to quality-check incoming flows. For Business Central in cloud (SaaS) mode, Microsoft itself acts as a certified Access Point, simplifying configuration — activate the Belgian localisation module and configure the company’s VAT identifiers.
For Dynamics 365 Finance (version 10.0.36+), the Electronic Invoicing Service (EIS) covers the Belgian Peppol channel via its electronic compliance features.
Odoo (Headquarters: Ramillies, Belgium)
Odoo has a natural advantage on this topic: its global headquarters is in Ramillies, Wallonia, and the Belgian localisation is maintained in-house. The l10n_be_edi_peppol module (available since Odoo 16.0, included by default in Odoo 17.0 and 18.0) turns Odoo directly into a Peppol Access Point — no third-party intermediary needed. Activation is done via Settings > Modules > Belgium > Peppol.
The benefit: Access Point costs are included in the Odoo.com subscription. One thing to watch on Odoo 16-to-17 or 17-to-18 migrations: verify that VAT identifier mapping rules were properly migrated, as several customers have reported format breaks after major version upgrades.
Sage X3 and Cegid XRP
Neither Sage X3 nor Cegid XRP includes a native Peppol Access Point for Belgium. Compliance runs through certified partners: Tungsten Network, Edicom, Basware, Banqup (a Belgian specialist), or CodaBox (historically strong with Belgian accounting firms). These partners interface with the ERP via standardised EDI connectors. The integration is typically a 4-to-8-week project depending on flow complexity.
What Belgian Businesses Should Expect in 2027–2028
2027: End of Soft Transition, Active Enforcement
2027 marks the definitive end of any operational tolerance. The Belgian Federal Finance Service has announced that targeted audits on Peppol flows will intensify from the second half of 2027 onward, particularly for businesses with high invoice volumes. The penalties — which apply per invoice — create considerable financial risk for mid-market companies still working around the system via PDFs.
Additionally, the enhanced deduction (up to 120%) for Peppol compliance costs (software, training, consulting) granted for the 2024–2027 period expires on 31 December 2027. Projects still mid-deployment have an interest in billing compliance costs before that date.
2028: Near-Real-Time VAT Reporting — Phase 2
The next major milestone is set for 1 January 2028: Belgium will introduce a near-real-time VAT reporting system, modelled on Spain’s SII or Italy’s SDI. The Belgian government approved the relevant legislation, confirmed by Edicom and other regulatory sources.
Technically, this system will use a Peppol 5-corner model: businesses will continue exchanging structured invoices via the Peppol network (as they do today), while the fourth corner — the Belgian tax authority — simultaneously receives a copy of the VAT data for each transaction. The annual VAT client listing will be abolished for businesses using this channel, reducing overall reporting overhead.
Companies that have built a clean Peppol integration — with a genuine end-to-end XML flow rather than a manual workaround — will be better positioned to absorb this second regulatory wave without a full redesign.
Compliance Checklist: 8 Checks to Complete Before End of 2026
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Your VAT number is registered in the Peppol directory — verify on directory.peppol.eu that your identifier BE:0208+XXXXXXXXXX appears and points to an active Access Point.
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Your ERP is emitting in BIS Billing 3.0 — not just generic UBL 2.1. Ask your vendor for a compliance certificate or test via the official Peppol validator.
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Your top 50 suppliers have been checked — map their Peppol status. Document a fallback for those not yet enrolled.
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Credit notes have been tested — send and receive a test credit note with at least one supplier partner.
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Your IT team knows how to handle an AS4 error — Peppol rejections generate AS4 error codes. Your service desk must have a documented handling procedure.
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Legal archiving is configured — electronic invoices must be retained for 7 years in a tamper-proof format. Verify that your DMS (document management system) or archiving solution is configured accordingly.
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Your foreign subsidiaries supplying into Belgium are informed — a French or Dutch entity invoicing a Belgian subsidiary is subject to Belgian Peppol requirements on the receiving side.
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Your statutory auditor is up to speed — Peppol flows change the accounting audit trail. Make sure your auditor has documentation of the new invoice circuit for the 2026 audit.
Belgium as a European Laboratory
Nine months in, Belgium demonstrates that a national mandate for B2B e-invoicing can reach mass adoption in under a year — given sustained government communication, a mature certified solutions ecosystem, and a progressive but credible sanctions timeline.
What France, Germany, and the Netherlands can take from the Belgian rollout: Peppol registration is a necessary but insufficient condition. Real compliance is measured by the quality of the XML flow, the ability to receive invoices automatically in the ERP, and the robustness of accounting processes when a rejection occurs. Businesses that treated Peppol as an IT project rather than a cross-functional finance-IT initiative are the ones experiencing the most friction in 2026.
For CIOs and CFOs still mid-deployment, the window for compliance without major risk is closing. The first targeted audits are expected in the second half of 2027.
For more background, see our complete guide to mandatory Peppol e-invoicing in Belgium, our analysis of enforcement penalties active since 1 April 2026, and our article on AFAS Profit 8 as a Peppol service provider in Belgium.
