Mandatory E-invoicing in Belgium

The Belgian Ministry of Finance intends to introduce mandatory e-invoicing in B2B transactions as of July 2023. The legislation for B2B e-invoicing is expected to be proposed in the first half of 2022.

The introduction of the Belgian B2B e-invoicing will probably take place in a phased approach:

Until now, B2G e-invoicing has only been mandatory in selected federal states in Belgium. Lately, the government has made the decision to extend it to the entire country. Assumed timeline looks as follows:

  • Phase I: October 2022: Public contracts and concessions with a minimum estimated value of EUR 215 000
  • Phase II: April 2023: Public contracts and concessions with a minimum estimated value of EUR 30 000
  • Phase III: October 2023: Public contracts and concessions with an estimated value of EUR 30 000 or below

Contract values below EUR 3000 are exempt from the e-invoicing obligation.

As a common standard for B2B e-invoicing, Belgium will probably adopt the PEPPOL framework (as for B2G transactions). Starting from the four-corner model, the Belgian tax authority will most probably upgrade to the six-corner model.

E-invoicing: four-corner model

In the PEPPOL four-corner model, the buyer and the supplier exchange e-invoices through an Access Point, which is a PEPPOL certified service provider providing data security and compliance with the PEPPOL standards (such as UBL format and AS4 communication protocol).

E-invoicing: six-corner model

In the six-corner model, the buyer’s and the supplier’s Access Points also exchange data with the Access Point of the General Administration of Taxation. Belgium is not opting for any government-owned e-invoicing platform (like Chorus Pro in France or SDI in Italy). Instead, a private Access Point (corner five) will be chosen for the purpose of providing e-invoicing services.

Due to the short time frame of implementing the obligation for SMEs to receive e-invoices, there will be the possibility to use the Belgian e-invoicing platform Hermes, which can currently be used by companies in B2B transactions. The platform enables the receipt of e-invoices and conversion into PDF documents, which are sent to the company by email.

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