Since 1 January 2026, e-invoicing has been mandatory for almost every Belgian business owner. There are exceptions, and you may be one of them. In this article we explain it simply: who has to e-invoice, who doesn't, and what to watch out for if you have customers who are exempt.
What exactly is e-invoicing?
We're not talking about a PDF you email to your customer. A real e-invoice is a digital file in a fixed format (such as Peppol BIS 3.0) that can be processed automatically by accounting software. The invoice goes straight from your system to your customer's, without an attachment.
Who has to send e-invoices?
In short:
- All VAT-registered businesses in Belgium
- That supply goods or services to other VAT-registered businesses
- And where the invoice relates to a VAT-taxable transaction in Belgium
So do you work B2B and invoice with VAT? Then you have to switch. You'll find the official explanation from the Belgian FPS Finance.
These businesses are exempt
There are four major exceptions. Do you recognise yourself in one of them? Then you are (for now) exempt from the e-invoicing obligation.
1. You are in bankruptcy
Has your business been declared bankrupt? Then you no longer have to send or receive e-invoices.
2. You only have a Belgian VAT number, but no permanent establishment
Do you have no fixed place in Belgium (such as an office, workshop or warehouse)? Then e-invoicing is outside the scope for you.
3. You work under a flat-rate VAT scheme
Are you a small business owner with a flat-rate scheme (e.g. in hospitality or agriculture)? Then you don't have to switch yet. Although that scheme will disappear by 2028 in any case.
4. You only supply exempt services (Art. 44 of the VAT Code)
Think of doctors, insurance brokers or educational institutions. They don't have to send e-invoices, because their services are completely VAT-exempt.
Note: even if you don't have to send e-invoices, you must be able to receive them
Since January 2026, almost every business with a Belgian VAT number must also be able to receive e-invoices. Only businesses without a permanent establishment or that are bankrupt escape this. So make sure your accounting or invoicing software is ready for it.
Can you still send a PDF?
No, not if you fall under the obligation. Since January 2026 you must send an e-invoice via the Peppol network or in a format that meets the European standard EN16931. PDF, Word or Excel no longer count as a "real" invoice.
What should you do now?
- Check whether you fall under the obligation
- Make sure your software is Peppol-ready. Already invoicing with NumNum? Then you're well on your way. If not, it's best to switch now.
- Communicate with your customers. You may no longer send ordinary invoices to businesses that fall under the obligation. Note: they may even refuse your paper or PDF invoice.
Peppol in NumNum
Peppol e-invoicing is included in NumNum. We handle your registration on the Peppol network and your Peppol address. Your invoices go straight into your customer's accounting software, and purchase invoices that arrive via Peppol end up in one place, with your expenses. Not sure whether the obligation applies to you? Ask your accountant, who gets free access to your account, or contact us.
