New practical rules for e-invoicing: royal decree of 8 July 2025 published. On 14 July 2025, the Belgian Official Gazette published the long-awaited royal decree that further clarifies the practical implementation of mandatory electronic invoicing from 1 January 2026. Among other things, the decree amends royal decrees no. 1, 8 and 44 and contains provisions on the permitted format, the transmission of structured electronic invoices and additional penalty provisions.
Below you will find an overview of the main points.
You can read the royal decree itself via this link (in Dutch and French).
1. Format and transmission
The royal decree confirms that Peppol BIS Billing 3.0 (UBL) is the standard format for structured electronic invoices.
- Deviating from this format is only possible if both parties agree to it explicitly and bilaterally, and provided the format used complies with the EN 16931 standard.
- Peppol is also the standard network for transmission. You can only use another channel with an explicit mutual agreement.
Importantly, businesses must always be Peppol-ready. Even those who agree on a different format with all their trading partners must still be able to send and receive invoices in Peppol BIS format.
In addition, the administration expects future e-reporting (possible obligation from 2028) to use the same (adapted) Peppol BIS XML structures.
2. VAT rounding rules
The decree changes how you may round VAT amounts in a structured electronic invoice.
- The decree no longer allows rounding at line level. You may only round VAT on the total amount per rate.
- Businesses that still round at line level must adapt their calculation and export scripts in time to avoid cent differences.
Note: the royal decree currently does not explicitly state that you must round per rate, although the Peppol BIS specification requires this. We expect a technical correction of the royal decree to put this right.
3. New administrative penalty
The decree introduces a new fine for businesses that are unable to send or receive structured invoices via the Peppol network:
- € 1,500 for a first infringement
- € 3,000 for a second infringement
- € 5,000 for each subsequent finding
The administration assesses fines per quarter. Existing penalties for incomplete or incorrect invoices remain unchanged and also apply to electronic invoices.
4. Technical and operational points of attention
- Other formats via Peppol: it is technically possible to send a format other than Peppol BIS over the Peppol network, provided both parties agree to it.
- Archiving: Peppol only handles the transport. Responsibility for keeping invoices in line with VAT legislation remains with the business.
- B2C situations: businesses with only B2C sales must also register on Peppol in order to receive electronic purchase invoices and to be able to send electronic sales invoices.
5. Looking ahead
Although this royal decree provides an important practical framework, we expect further amendments.
- Correction of the royal decree regarding the rounding provisions
- Publication of an amendment stating that taxable persons not established in Belgium do not have to receive structured electronic invoices.
We will continue to follow these developments and will report again as soon as new decrees or circulars appear.
More on Peppol and the legal obligations around e-invoicing in E-facturatie Ontcijferd (in Dutch).
Want to know whether the obligation applies to you? Read our guide to the Belgium e-invoicing mandate and take the test.