Regulatory updates - Belgium

From January 1, 2026, Belgium will require all VAT-registered businesses established in Belgium to issue and receive structured electronic invoices (e-invoices) for domestic B2B transactions. This obligation is part of a broader VAT reform aimed at digitalization, fraud prevention, and alignment with the EU's "VAT in the Digital Age" (ViDA) directive.

Key features:

• E-invoices must comply with European standards (Peppol/EN 16931)
• The obligation applies to transactions where both supplier and customer are established in Belgium. Non-established entities with a Belgian VAT number will now be excluded from the scope.
• Fallback provision: If, for technical reasons, the recipient is not able to receive a structured e-invoice (e.g. lack of technical means), the issuer is temporarily not required to issue a structured e-invoice for that transaction. Instead, the issuer must still issue an invoice in another form (e.g., paper or PDF). However, this does not exempt the recipient from their obligation to become compliant.

More information can be found in the draft law about the various provisions on Value Added Tax (VAT) in the following link (Dutch and French).

FPS Finance has recently announced a three-month grace period, at the beginning of 2026, for Belgian taxpayers, acknowledging the significant operational challenges posed by the new e-invoicing requirements. During this transition period, companies that struggle to meet all obligations despite their best efforts will not face penalties. No sanctions will be imposed for non-compliance with the e-invoicing requirements throughout these three months.

The grace period, largely aimed at companies that have made sufficient implementation efforts but still face technical challenges, applies to the following infractions directly related to the new obligation:

• Companies that do not yet have the required technical capabilities to send and/or receive structured electronic invoices (either completely or for specific transactions, such as self-billing).
• Companies unable to issue structured electronic invoices despite being obligated to do so because their systems or third-party solutions do not yet support valid electronic invoice issuance.

Companies that have not made adequate preparations are urged to comply as soon as possible. The announcement explicitly states that, regardless of a grace period, the intention is not to grant a general extension of the mandate.

More information on the grace period announced by FPS Finance can be found here.

After Belgium adopted e-invoicing legislation on February 6, 2024, the Business Experts Group reassessed the Hermes platform in July 2024 and determined it should be decommissioned. 

The government now considers there are sufficient IT providers in the market to support e-invoicing compliance, enabling a safe and structured phase-out of Hermes. The decommissioning process has begun with BOSA SD terminating Hermes Integration Agreements. 

Organizations currently utilizing the Hermes solution should promptly evaluate and select an alternative e-invoicing option to ensure continued compliance with the January 2026 mandate. Although the solution will be deactivated at the end of 2025, users will maintain access to consultation mode until March 31, 2026.