Perspectives · Invoicing mandates
Belgium's e-invoicing tolerance runs out on 31 March
Since 1 January 2026, a business registered for VAT and established in Belgium has had to send and receive structured electronic invoices in its dealings with other Belgian VAT-registered businesses. In December 2025 the tax administration said it would not impose sanctions for infringements of the new obligation committed between 1 January and 31 March 2026, provided the business could show it had taken reasonable and timely steps. That tolerance is conditional, assessed case by case, and it ends on 31 March. For many groups the uncertainty is about their own position: which Belgian entities are connected to a network, and who confirmed it. This perspective is general information, not legal advice.
23 February 2026 · Invoicing mandates
The mandate
Mandatory in January, enforced from April
A structured electronic invoice is a machine-readable file in a format that meets the European standard EN 16931, exchanged over a network. A PDF attached to an email does not qualify, whatever the covering note calls it. From 1 January 2026, the structured form is the required form of invoice between VAT taxable persons established in Belgium for their business-to-business supplies. The default route is the Peppol BIS format carried over the Peppol network; another network and another format may be used where both parties agree and the format still meets the European standard, but that agreement has to be real and recorded.
What the administration announced in December 2025 was a tolerance on sanctions, not a delay. No penalties for infringements of the new e-invoicing obligation committed between 1 January and 31 March 2026, where the taxpayer can demonstrate reasonable and timely steps towards compliance. It is not automatic, it is not general, and each case is assessed on its own facts. A business that did nothing until March was never inside it. The administration was explicit that there would be no general postponement: the obligation applied from January and only the sanction was held back.
From 1 April 2026 the penalty regime applies to a taxable person that lacks the technical means to issue and receive structured invoices. It runs at EUR 1,500 for a first infringement, EUR 3,000 for a second identified at least three months after the first, and EUR 5,000 for those that follow. The ordinary penalties for late or incorrect invoicing were never suspended, and a business that cannot yet exchange structured invoices still has to invoice.
The quiet entity
The Belgian company with no finance team
An operating company with an accounts-payable department has spent a year on this. The exposure in a fund or private-equity group sits somewhere quieter: the Belgian holding company, the property vehicle, the acquisition SPV that issues four invoices a year and receives a handful from its lawyers and its domiciliation agent. It has no finance system of its own, its bookkeeping sits with an external office, and its directors assumed the administrator had dealt with the connection.
The failure mode is silence. A supplier sends a structured invoice, the entity has no access point to receive it, and the document is simply not delivered. Nobody gets an error. The first sign is a supplier chasing payment, or a deduction queried long afterwards. Multiply that by the fifteen or twenty Belgian entities in a mid-sized structure, each served by a different provider under a different engagement letter, and the group has fifteen or twenty separate readiness questions and no single place that answers them.
The readiness line
Six questions per Belgian entity
For each entity established in Belgium: is it within the obligation, is it registered on the network, which access point provider carries it, which identifier is registered against it, can it receive as well as issue, and who inside the group is accountable for that answer. Six questions with six short answers, and someone can read down the column and see which cells are empty. Two of them go wrong more than the rest. The identifier registered on the network should correspond to the entity's VAT number and legal name as the register actually holds them, because a counterparty looking the entity up will search on those and a near miss returns nothing. And the accountable name should be a person, not a firm. "The administrator handles it" is the sentence behind most of the gaps that surfaced in January, because it was true of somebody at the administrator and of nobody in particular.
In Alethia
Peppol status belongs on the entity record
Network readiness fits an entity record without being bent into it. It is an attribute of a Belgian entity, with a document behind it in the form of the access point agreement, a named owner, and a date by which it had to be true. Held that way it survives the departure of the person who arranged it, which is more than can be said for the confirmation email that usually carries this fact.
Reading that attribute across every Belgian entity in the register takes a moment, and every reader gets the same answer, because there is one record and no mailbox to search. Alethia connects nobody to Peppol and sends nobody's invoices. The obligation it does carry is the dated one sitting on each Belgian entity, with the evidence attached and the name of whoever confirmed the position still legible a year from now.
Questions
The mandate and the tolerance period
Did the tolerance push the obligation back to April?
No. The obligation applied from 1 January 2026. What the administration granted was a conditional suspension of sanctions for infringements committed in the first three months, available only to a business that can show it took reasonable and timely steps. A business with no steps to show was never inside it.
Does a holding company that issues almost no invoices fall outside the rules?
Volume is not the test. The obligation follows VAT status and establishment in Belgium, whatever the number of documents a company produces in a year, and receiving capability matters as much as issuing. Whether a particular entity is caught depends on its VAT position, and the government's own scope checker on einvoice.belgium.be is the place to settle it entity by entity.
Is Peppol compulsory, or can we keep our existing exchange arrangement?
Peppol BIS over the Peppol network is the default. A different network and format may be used where both parties agree to it and the format meets EN 16931. If a group relies on that, the agreement and the format conformity should be documented per counterparty and never assumed.
Six questions, one line per Belgian entity
Scope, network registration, access point provider, identifier, receiving capability and the person accountable. A blank cell in that line is the finding, and it is far cheaper to see in February than in a supplier's chaser in May.