As electronic invoicing becomes mandatory in more and more EU countries, understanding whether you are required to use Peppol for invoicing in Belgium is crucial. Peppol (Pan-European Public Procurement On-Line) facilitates structured electronic invoicing for businesses and public institutions across Europe. In this article, we break down when you are required to use Peppol, who qualifies, and when you don’t need to.
📌 When is e-Invoicing via Peppol Mandatory?
In Belgium, the following general obligations apply:
From January 1, 2026: All VAT-registered Belgian businesses that invoice other businesses within Belgium (B2B) must issue invoices as structured electronic invoices in a format compliant with the European standard EN 16931 (Peppol or equivalent).
For invoices to the government (B2G): As of March 1, 2024, all invoices to Belgian public authorities must be issued electronically via Peppol or related networks for new contracts.
Exemption for B2C: There is no requirement for invoicing to consumers (B2C) towards private individuals.
Exemptions apply: Certain categories of businesses, such as those carrying out only exempt transactions under Article 44 of the Belgian VAT Code, businesses under the special forfait system, or bankrupt businesses, are not required to comply.
Non-established businesses in Belgium: These businesses (without a fixed establishment in Belgium) are currently not within the scope of the receiving obligation (according to the current interpretation).
🧾 Specific Requirements per Business Type
Here's a breakdown of business forms and the e-invoicing obligation:
Business Type | Required to Use Peppol? | When Exactly / Under What Conditions |
BV (Private Limited Company) | ✅ Yes | From January 1, 2026, for B2B invoicing within Belgium, if VAT-registered. |
NV (Public Limited Company) | ✅ Yes | Same as above: VAT-registered + Belgian client + local transaction. |
CV (Cooperative Company) | ✅ Yes | If VAT-registered, invoices to other businesses, Belgian VAT. |
VOF (General Partnership) | ✅ Yes | If VAT-registered and invoices to businesses within Belgium. |
CommV (Limited Partnership) | ✅ Yes | If VAT-registered and invoices to businesses. |
Sole Proprietorship | ✅ Yes | If VAT-registered and invoices B2B within Belgium. |
VZW / ASBL (Non-profit Organization) | ⚠️ Maybe | Only if VAT-registered and invoices to other businesses in Belgium. |
Foundation / FUP / PS | ⚠️ Maybe | Depends on VAT-registration and if the business activities are taxable. |
Summary and Next Steps:
VAT-registered businesses (e.g., BV, NV, SMEs, etc.) invoicing other businesses in Belgium are required to issue structured e-invoices via Peppol or an equivalent format starting January 1, 2026.
Non-profits (VZW/ASBL) not VAT-registered or mainly invoicing consumers are not required but may choose e-invoicing to optimize their processes.
Important: Begin preparations now to ensure compliance when the deadline arrives!
✅ When Are Self-Employed Individuals Exempt from VAT?
In Belgium, self-employed individuals (and small businesses) can be exempt from VAT under certain conditions, offering a simplified process with fewer administrative obligations. Key points:
Small Enterprise Exemption: If your annual turnover in Belgium does not exceed €25,000 (excluding VAT), you are eligible for VAT exemption.
This exemption applies regardless of your business form (sole proprietorship, company, etc.), as long as you meet the conditions.
Advantages: No need to charge VAT, and no periodic VAT returns to submit.
Disadvantages: You cannot claim VAT back on business expenses.
Exceptions: Certain transactions or sectors are excluded or have specific rules (e.g., exempt transactions under Article 44 of the VAT law or specific forfait regimes).
⚠️ When Must VAT-Exempt Self-Employed Individuals Still Use Peppol for e-Invoicing?
The obligation to use Peppol for e-invoicing does not solely depend on VAT exemption but on whether the invoice is addressed to another business (B2B), in Belgium, and whether the transaction is taxable.
Important Criteria for e-Invoicing Obligation:
The invoice must come from a VAT-registered entity in Belgium performing a taxable supply within Belgium.
The customer/recipient must be another VAT-registered entity (B2B) or a business based in Belgium.
The transaction must be within Belgium and subject to VAT (not exempt under Article 44 of the VAT law).
Deadline: e-Invoicing becomes mandatory for B2B transactions in Belgium starting January 1, 2026.
Even if you are VAT-exempt, there can still be situations where you must use Peppol e-invoicing:
A VAT-exempt self-employed individual with a turnover of less than €25,000 may still be required to use Peppol for B2B invoicing if the transaction is taxable and within Belgium.
📋 Summary in a Table: e-Invoicing Requirements
Situation | VAT Exempt? | Required for Peppol/e-Invoicing? | Required to Use Peppol to Receive? |
Self-employed with turnover < €25,000, invoicing consumers (B2C) | Yes | No | No |
Self-employed with turnover < €25,000, invoicing a business (B2B), taxable supply | Yes | Yes, starting January 1, 2026 | Yes, if receiving from VAT-registered businesses |
Self-employed with turnover < €25,000, invoicing a business, exempt supply (Article 44) | Yes | No | No |
Self-employed with turnover > €25,000 (or other VAT-registered business) | No (VAT-registered) | Yes (if criteria met) | Yes |
Franchisee, VAT-registered | Yes | ✅ Yes, starting January 1, 2026 | Yes, if receiving from VAT-registered businesses |
Franchisee, non-VAT registered | No | No | No |
Practical Example:
If you're self-employed with turnover under €25,000 and invoice individuals (B2C): No obligation to use Peppol.
If you invoice a business (B2B) with taxable activities: You must use Peppol starting January 1, 2026.
If your activities are fully exempt under Article 44 (e.g., medical services): No obligation to use Peppol.
🔍 Final Thoughts:
Understanding when Peppol e-invoicing applies is crucial for ensuring compliance and avoiding penalties. For self-employed individuals and businesses in Belgium, the key factors are whether you're VAT-registered, whether the transaction is taxable, and whether it involves another VAT-registered business. Be sure to prepare for the mandatory shift to Peppol in 2026 and consult a tax advisor if you're unsure about your specific situation.