The Dutch government officially confirmed on 11 September 2026 that structured B2B e-invoicing will be mandatory from 1 July 2030, with transactional digital reporting following on 1 July 2031 (Rijksoverheid.nl). Belgium made the same move four years earlier and has already accumulated nine months of real-world experience. The mistakes made there define exactly what Dutch CIOs and CFOs must anticipate now.
Context: ViDA sets the direction, Belgium already went there
The mandate sits within the ViDA (VAT in the Digital Age) framework — the EU-wide reform of the VAT Directive. The Netherlands is going further than ViDA strictly requires by extending the obligation to domestic B2B transactions, not just intra-EU flows. The format is EN 16931 with the NLCIUS profile, exchanged over the Peppol network — the same standard Belgium uses. The only exemption: businesses under the KOR (Kleine Ondernemersregeling) scheme with annual turnover below €20,000 (ibid.).
Belgium went live four years before the Netherlands. Penalties have been enforced since 1 April 2026: €1,500 per non-compliant invoice for a first offence — per invoice, not per company. That rollout left a detailed map of traps to avoid.
The most expensive mistake: Peppol registration is not the same as compliance
The majority of Belgian compliance incidents share the same pattern. A business obtains a Peppol account, configures its outbound invoices in structured UBL format, and considers the job done. It is still non-compliant.
The law imposes three simultaneous conditions:
- Be registered on Peppol as both a sender and a receiver
- Send invoices in structured format (UBL via Peppol — not a PDF attached to an email)
- Receive and automatically process incoming supplier invoices inside the ERP or accounting software
A business that continues to receive supplier invoices by email as PDFs — even with an active Peppol account — is non-compliant. For a Dutch company handling 500 supplier invoices a month, the potential exposure exceeds €700,000 in monthly penalties if the Belgian scale applies. Compliance runs through the ERP, not just through network registration.
What AFAS, Exact Online, SAP and Unit4 teams need to prepare
Starting positions vary significantly by platform.
AFAS obtained Peppol Service Provider certification in June 2026 with Profit 8. Structured sending and receiving are natively integrated: AFAS customers can activate the B2B Peppol flow without any third-party module.
Exact Online, the leading cloud ERP for Dutch SMEs, already includes full UBL/Peppol support. Activation is a configuration task, not a project.
SAP and Unit4 require a third-party Peppol Access Point (Pagero, Tungsten, or another OpenPeppol-accredited operator) connected via API or middleware. Migrating to a fully compliant Peppol B2B flow typically takes 6 to 18 months depending on scope complexity: multi-entity structures, cross-border coverage, accounting integration, and inbound flow validation. Access Points already certified for Belgium can operate in the Netherlands on the same NLCIUS standard — a concrete operational advantage for Benelux groups (VATupdate, 23 September 2026).
Three milestones to put in your project plan
- Autumn 2026: public consultation (internet-consultatie) on the draft legislation. The final technical standard and any additional exemptions will be confirmed at this stage.
- Before summer 2027: submission of the bill to the Tweede Kamer (House of Representatives). Legislation is not expected to pass before 2028.
- 2028–2030: the implementation window. An SAP or Unit4 project started in 2028 lands on time; started in 2029, it carries real risk.
Further reading: our analysis of the official Belastingdienst announcement and the full regulatory timeline and our coverage of the Belgian penalties enforced since April 2026 — €1,500 per invoice.
