e-Invoicing in Belgium

Mandatory E-invoicing in Belgium

Learn how to get your company ready to exchange documents in accordance with regulations in Belgium

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Mandatory E-invoicing in Belgium

Belgium has already introduced mandatory e-invoicing for B2G transactions. The Ministry of Finance does not intend to stop there, and it is likely that Belgium will start partially introducing mandatory B2B e-invoicing from July 2024

Who is obliged to use e-invoicing

Who is obliged to use e-invoicing 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.

Archiving requirements for e-invoicing

Is e-invoicing mandatory for B2B?

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.

E-invoicing Implementation timeline

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:

  • from January 2024: all taxpayers will be required to be able to receive e-invoices
  • from July 2024: large taxpayers will have to be able to issue e-invoices (turnover above €9 million)
  • From January 2025: medium taxpayers will have to be able to issue e-invoices (turnover between €7m and €9m)
  • From July 2025: other taxpayers will have to be able to issue e-invoices (below €7m)

E-invoicing process description

E-invoicing process description

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:

  • Manual upload – the respective interface does not only enable the suppliers to send structured invoices and credit notes, but also makes it possible for sender, recipient, and service provider to check the status of the sent documents.
  • Through PEPPOL – automatically via a PEPPOL Access Point.

E-invoicing process description

How integrity and authenticity may be ensured?

What is Mercurius Platform and how does it work?

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).

How integrity and authenticity may be ensured?

How can Comarch help?

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).

Why is Comarch the best choice?

We have 20+ years of experience in carrying out various EDI, e-invoicing, and other document exchange projects around the world. In those years, we have successfully connected more than 130,000 entities from over 60 countries.

  • 1. Legal compliance

    Full compliance with the latest data exchange regulations and modern data transfer standards

  • 2. Digitization

    Applying new technologies and IT solutions in order to streamline workflows and automate activities and procedures

  • 3. Individual approach

    Tailor-made solutions based on processes specific to each company – own road map and a suitable pace of changes

  • 4.Security

    Highest level of security for all sensitive and important company data

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