Electronic Invoicing and Tax Reporting in Belgium

At the B2G level, all suppliers of centralized public entities in the different regions of the country are obliged to issue electronic invoices, while public entities must be prepared to receive and process them digitally.

E-invoices to Belgian public administrations must be sent in accordance with the Peppol European interoperability model, which guarantees the standardization, security and traceability of the issuing and receiving process.

Invoices can be received by public entities in two ways:

1. Through the national Mercurius platform, Belgium’s centralized portal for receiving invoices from suppliers, enabling unified and efficient management for all public administrations.
2. Direct submission via the Peppol Access Point of the respective public entity, applicable where advanced or specialized infrastructure is already in place.

The adoption of B2G electronic invoicing in Belgium was carried out gradually, based on the value of public contracts. This phased approach allows both public administrations and suppliers to prepare adequately according to the volume of their operations.

Below is the official implementation timeline:

• November 1, 2022: The obligation to submit electronic invoices came into effect for all public contracts equal to or above the European threshold, i.e., €214,000 for goods and services, and €5,350,000 for works. This measure applies to all contracts awarded from that date onward.
• May 1, 2023: The obligation was extended to all public contracts equal to or above €30,000. This includes a larger volume of contractors and subcontractors at all levels of government.
• March 1, 2024: The requirement was further expanded to include contracts below €30,000, thus consolidating the general obligation to issue electronic invoices for virtually all public procurements in Belgium.

Exception: Contracts under €3,000 These contracts are exempt from the obligation, although each level of government (federal, regional, or local) may decide not to apply this exemption or may establish a different timeline for its application.

Belgium is further advancing its digital tax strategy with the introduction of e-Reporting, set to become mandatory in January 2028. This initiative complements the B2B electronic invoicing mandate and is part of a broader modernization effort to enhance VAT compliance and control.

e-Reporting consists of the near real-time electronic transmission of commercial transaction data to the tax authority. Unlike the traditional model based on periodic declarations, this system will allow the administration to receive detailed and structured information directly from companies' invoicing systems, facilitating proactive monitoring and control of VAT.

The Belgian e-Reporting system will be based on a “five-corner model” within the Peppol ecosystem, the same framework used for B2G and B2B electronic invoicing.

This model involves the following actors:

1. Supplier (invoice issuer)
2. Supplier’s Peppol Access Point
3. Customer (invoice recipient)
4. Customer’s Peppol Access Point
5. Belgian tax authority, which will receive a copy of the data in parallel

This approach ensures secure, traceable, and standardized communication among all parties involved, including the tax administration, without the need to create parallel reporting channels. In this way, the existing infrastructure is leveraged to reduce costs, technical complexity, and implementation time.