Electronic Invoicing in the Benelux Region: Latest Updates for Belgium, the Netherlands, and Luxembourg

Benelux made up of Belgium, Netherlands, and Luxembourg continues its electronic invoice adoption process. While it is already extensively implemented in public administration contracts regulated by European laws, the pace of progress varies when it comes to business-to-business transactions.

The electronic invoice in Belgium advances at various speeds

B2G Invoicing in Belgium

In the Business-to-Government (B2G) sector, there is a requirement to issue electronic invoices to all suppliers serving public institutions in the country. This mandate was introduced gradually, depending on the scale of public contracts.

The federal government operates on the Mercurius platform, which is linked to the Peppol network in PEPPOL BIS 3.0 format. All government agencies can access the Mercurius platform to receive invoices. Additionally, public administrations have the option to connect through their Peppol ID or opt for an alternative connection method. Peppol also allows the inclusion of attachments with the invoice in a structured format.

Electronic signature is not mandatory, and invoices must be retained for 7 years.

B2B Invoicing in Belgium

Vincent Van Peteghem, the Minister of Finance, has secured an agreement within the Council of Ministers for the mandatory implementation of electronic invoicing between companies starting from January 1, 2026. The Belgian government has recently submitted its proposal for mandatory B2B invoicing to the Belgian Parliament.

The transition to digital invoicing holds significant importance in addressing the VAT gap, which represents the variance between the government's anticipated VAT revenue and the actual receipts. It also emphasizes the ongoing simplification of administrative processes. On December 8, 2023, the Council of Ministers approved a draft law, in its second reading, mandating the use of structured electronic invoices. The draft law awaits the King's signature for its presentation to the House of Representatives.

As of January 1, 2026, all Belgian companies will be obligated to send and receive electronic invoices. The government has opted for the European PEPPOL network. Upon joining this network, a company becomes automatically interconnected with all other participants. This network is already in use across numerous EU member states. Importantly, taxpayers retain the flexibility to choose an alternative system through mutual agreement, provided it adheres to European standards regarding semantics and syntax.

Netherlands - No Changes in Electronic Invoicing 

In 2017, the Netherlands introduced a requirement for the use of electronic invoicing in public tenders. Currently, both central public administrations and contracting authorities are mandated to be capable of receiving and processing invoices. Moreover, suppliers with contracts dated after January 2021 are obliged to issue electronic invoices, while those with contracts preceding that date have the option to do so voluntarily.

Central public administrations connect to the Digipoort platform, which is linked to the PEPPOL network, allowing electronic invoices to be transmitted in PEPPOL BIS 3.0 format. EDICOM has received certification as an authorized PEPPOL provider for electronic invoicing services in the Netherlands from the Dutch PEPPOL authority, Nederlandse Peppolautoriteit (NPA). Any company has the capability to utilize the EDICOM platform for sending and receiving invoices through the PEPPOL network.

Similar to the situation in Belgium, non-central public administrations typically connect through their individual Peppol ID. Since January 2021, oversight of these matters has been under the Nederandse Peppol Autoriteit, affiliated with the Ministry of the Interior. The use of electronic signatures is not obligatory, and invoices must be retained for a period of 7 years.

Private companies are permitted to issue electronic invoices, provided they have the approval of their customers, and the invoices comply with legal requirements.

Luxembourg, mandatory B2G electronic invoicing

B2G invoicing is compulsory for all businesses in Luxembourg, and widespread adoption was completed by March 2023.

Electronic invoices must be transmitted through the PEPPOL network following PEPPOL-BIS 3.0 standards. 

Foreign companies selling products or services to public entities in Luxembourg are also required to send their invoices via Peppol.

Regarding compliance management, since 2011, the Luxembourg tax authority has the authority to request companies to submit the electronic FAIA file containing all accounting information in case of an audit.

Global Electronic Invoicing Platform

Utilizing electronic invoicing provides a competitive edge for any company seeking to secure public contracts. Therefore, partnering with an international electronic invoicing solution opens opportunities in the Benelux market countries: the Netherlands, Luxembourg, and Belgium.

The platform guarantees a connection to the PEPPOL network as a certified Peppol Access Point., making it an ideal solution for operations in the Benelux public market. Additionally, it allows for any other form of connection (AS4, web service, etc.) chosen by public administrations with the flexibility to do so, as seen in the case of Belgium.

Moreover, EDICOM assures that the platform evolves and adjusts to new technical and legal requirements imposed by governments and tax authorities. This service is critical because the invoicing system is in a constant state of evolution.

EDICOM coordinates GOVEIN2019 project (Action No: 2019-EU-IA-0046)

*The contents of this publication belong solely to EDICOM GROUP and do not necessarily reflect the opinion of the European Union.