Electronic Invoicing

The Minister of Finance plans to introduce electronic invoicing and possibly an electronic reporting system as part of the “Digital VAT” proposal of the European Commission. Electronic invoices will have to be issued in a structured format such as XML via the PEPPOL network. PDF invoices will no longer be considered valid.

Electronic invoicing will gradually become mandatory in Belgium, as follows:

• From 1/07/2024, large enterprises with an annual turnover exceeding €9,000,000 (excluding VAT) will be required to use it.
• From 1/01/2025, it will apply to companies with a turnover exceeding €700,000 (excluding VAT) but less than or equal to €9,000,000 (excluding VAT).
• From 1/07/2025, all other VAT-registered companies, except small exempted businesses and farmers under the flat-rate scheme, will be affected.
• Finally, from 1/01/2028, even small exempted businesses and farmers under the flat-rate scheme will have to adopt electronic invoicing.

Currently, only electronic invoicing is planned, with no concrete measures for electronic reporting. However, the Minister of Finance is in favor of such a system. The introduction of electronic invoicing within the specified timelines is not certain, and the situation is closely monitored. VAT-registered businesses should prepare and adapt their invoicing systems to comply with the new requirements, as this could have a significant impact on their operations.