Mandatory E-invoicing in Belgium
Learn how to get your company ready to exchange documents in accordance with regulations in Belgium
Learn how to get your company ready to exchange documents in accordance with regulations in Belgium
All Belgian public bodies are already obliged to be able to receive and process electronic invoices in the context of public procurement, which makes it mandatory for all federal government suppliers to issue electronic invoices (transposition of Directive 2014/55/EU). This obligation applies to contracts above EUR 30,000, and from October 2023 it will also cover contracts below this amount. Invoices below EUR 3,000 are exempt.
In Belgium, measures to reform the tax system, including the invoice exchange model and the transition to electronic invoicing, have just started. The Belgian Ministry of Finance has announced that the reforms will focus on electronic invoicing in the private sector in B2B transactions. To make this possible, all companies have been registered on the Hermes platform, which will enable e-invoices to be sent in B2B relations. Currently, B2B e-invoicing is possible provided that the seller and the buyer agree to it.
The main focus will be on reporting data from invoices, and the goal of mandatory e-invoicing will be achieved in stages. PEPPOL is likely to be the preferred standard for e-invoicing, which will include near-live e-reports to replace the annual customer inventory report.
Due to the current legislative impasse around comprehensive tax reforms in Belgium, and given the complexity of the Belgian legal framework, which results in the possibility of attempting reforms only after the upcoming elections in the summer of 2024, it is likely that the originally planned 2024 entry into the life of the invoicing obligation will only be implemented in 2026.
The original plan to implement mandatory e-invoicing in B2B relations was as follows:
Belgium is likely to adopt the PEPPOL framework, the standard for B2B e-invoicing, which is also used for B2G transactions. The Belgian tax authorities will probably adopt the "four-corner model" as a base.
Suppliers to the public sector have two options to submit their invoices:
B2G invoices are to be submitted through the Mercurius platform. This platform was developed by the Belgian government, and is connected to the PEPPOL network. Invoices and credit notes exchanged via the Mercurius platform have to be compliant with the PEPPOL BIS 3.0 document format.
Mercurius facilitates the integration of systems between senders and recipients. It is equipped with an online portal that is accessible to all Belgian organizations and provides tracking services for senders, recipients and their service providers. The portal also allows manual upload of invoices. Mercurius is fully and exclusively aligned with PEPPOL. The platform can also convert uploaded documents from a machine readable format (XML) to a human readable format (PDF).
Comarch is a certified PEPPOL access point. Under the four-corner PEPPOL model, the buyer and supplier exchange invoices via an access point, which is a PEPPOL certified service provider that ensures data security and compliance with PEPPOL standards (for example, UBL format or AS4 communication protocol).
