Belgium Updates E-Invoicing Guidance and Progresses ViDA Legislation

The Belgian government is advancing its digital tax architecture through concurrent legislative and administrative updates. These developments include the ministerial approval of a draft law designed to partially transpose the European Union’s VAT in the Digital Age (ViDA) directive, alongside the publication of the first major revision to the official electronic invoicing FAQ since the national mandate went live.

Clarifications Provided in Updated E-Invoicing FAQ

The Belgian tax authorities have published the first update to the official electronic invoicing FAQ since the mandate entered into force. This revision modifies existing guidelines and adds seven new questions to offer clearer administrative and technical direction for businesses.

The key updates focus on the following operational areas:

• Peppol Delivery Delays: Technical delays in invoice transmission via the Peppol network are now formally acknowledged. If the delivery of an electronic invoice exceeds one business day, the software supplier is required to investigate the cause.
• Reverse Charge Rules: Invoices that do not contain the specific reference to Article 20 §3 should not be automatically rejected, provided that the terms “reverse charge” or “reverse charging of VAT” are present elsewhere in the document. These mandatory details can be positioned within an additional information or unstructured field.
• Incorrectly Received Invoices: When a business receives an incoming invoice intended for a different recipient, it must not book the transaction. The document must be electronically rejected through the Peppol network using the specific invoice response code “RE.” Software applications must support this electronic rejection protocol, as it functions as the official channel and formal audit trail during disputes.
• Erroneous Outgoing Invoices: If an invoice containing chargeable VAT is sent to the wrong recipient, it cannot simply be deleted from the billing system. The issuer must register the invoice and include it in their periodic VAT return. A corrective credit note must then be issued, referencing the unique Peppol invoice ID of the original document to guarantee a compliant audit trail.
• Self-Billing Procedures: Under self-billing frameworks, the supplier or service provider must register on the Peppol network because they represent the party receiving the invoices. This arrangement continues to require a prior agreement between the participating trading partners, alongside individual acceptance of each self-billed invoice or credit note.

Draft Law Approved for Partial ViDA Transposition

The Belgian Council of Ministers has approved a preliminary draft law designed to amend the national VAT Code. This measure serves to partially transpose the European Union’s VAT in the Digital Age (ViDA) Directive (Directive 2025/516 of 11 March 2025) and addresses two distinct sets of provisions:

• Pillar 2 (Platform Economy): Measures under Article 2 refine and clarify the VAT principles introduced by the 2017 and 2019 e-commerce directives, which govern distance sales of goods and cross-border services.
• Pillar 3 (Single VAT Registration): Measures under Article 4 repeal two specific provisions of the VAT Directive regarding the documentary and reporting obligations applicable to the call-off stock regime. These repeals will take effect on July 1, 2029.

The draft law references effective application dates of January 1, 2027, and July 1, 2029, matching the phased implementation timeline set out by the ViDA Directive. The text has been submitted to the Council of State for an official opinion before continuing through the standard legislative procedure.

A subsequent legislative phase will be required to implement Pillar 1 of the directive, which covers Digital Reporting Requirements (DRR). Consequently, businesses in Belgium should expect separate legal measures addressing the electronic invoicing and DRR frameworks ahead of the final 2030 deadline, which will introduce substantial adjustments for corporate invoicing systems.

There’s more you should know about e-invoicing in Belgium – learn more about the new and upcoming regulations.