B2B, B2C, and B2G e-Invoicing in Belgium: Differences, Similarities, and Compliance

Belgium implemented mandatory e-invoicing for B2G transactions in March 2024. Moving forward, it is all set to implement B2B e-invoicing from January 2026 to comply with the digital VAT regulations and streamline the reporting process. 

The scope of B2B e-invoicing widens Belgium’s role in the growing digital VAT compliances within European countries. In contrast, B2C e-invoicing is unaffected by these mandates and retains optional status. 

This guide illustrates Belgium's critical differences, similarities, and compliances among B2B, B2C, and B2G e-invoicing systems.

What is E-Invoicing Belgium?

E-invoicing Belgium refers to the structured process of issuing, sending, and receiving invoices mandatorily electronically. Invoices must be issued in a structured format compliant with the EU e-invoicing standards. Further, PDF invoices will no longer hold validity and are optional with e-invoicing. 

The only legally accepted invoice is issued in the structured electronic Peppol-BIS format. The paper or PDF-formed versions can be presented, but no electronic validity is attributed to them as an invoice.

What are B2B, B2C, and B2G transactions in Belgium?

• B2B (Business to Business) Transaction: A B2B transaction is a transaction of goods or services for commercial purposes exchanged between two registered business entities.
• B2C (Business to Consumer) Transaction: A transaction in which the sale of goods or services from the business to the end-use consumer takes place. These kinds of transactions are usually made for personal use or final consumption.
• B2G (Business to Government) Transaction: Transactions entered between the registered business entities and public entities or government bodies are called B2G transactions. 

B2B E-invoicing in Belgium

Here are the key features of B2b e-Invoicing Belgium: 

Legal Framework

• Mandatory for all B2B transactions starting January 1, 2026.
• Governing law is the Belgian VAT law in alignment with the EU Directive 2014/55/EU.

Scope

• Applies to taxable transactions within Belgium between two enterprises liable to VAT.
• The issuer must be a VAT-taxable person established in Belgium.
• The customer must have a Belgian VAT number or be obliged to register for VAT in Belgium.

Transactions Exempted From the Obligation:

• Businesses in bankruptcy.
• Businesses operating under flat-rate VAT schemes (Article 56 VAT Code).
• Businesses making exempted transactions (Article 44 VAT Code).
• Non-residents who do not have a permanent establishment in Belgium.

Key Requirements

• Structured Format: Peppol-BIS or an EN 16931-compliant format for issuing e-invoices.
• Transmission: E-invoices should be submitted via certified PEPPOL Access Points.
• Acceptance: The customer cannot reject an electronic invoice.

Penalties for Non-compliance

• Proportional Penalties: 200% of VAT for non-issuance or incorrect invoices.
• Non-proportional penalties: From 50 to 5,000 Euros for non-compliance with the rules concerning invoicing.

Best Practice

• Switch to compliant e-invoicing software well in advance of the deadline in 2026.
• Periodically check the VAT obligations to identify gaps in compliance.
• Training of staff on new invoicing processes and legal requirements.

B2G E-invoicing in Belgium

The key features of B2G e-invoicing Belgium are as follows: 

Legal Framework

• Mandatory since November 2022, with a phased implementation based on contract values.
• November 2022: Mandatory for public contracts over EUR 215,000
• May 2023: Mandatory for contracts equal to or greater than EUR 30,000
• November 2023: Mandatory for contracts below EUR 30,000
• March 2024: Mandatory for all contracts with the public authorities.
• Exemption: Contracts under EUR 3,000 are excluded from the obligation

Key Requirements

• Structured Format: All invoices must be in the Peppol-BIS format.
• Delivery: Must be sent via PEPPOL-certified providers to ensure compliance.

Penalties for Non-Compliance

• Proportional Penalties: 200% of VAT for non-issuance or incorrect invoices.
• Non-proportional penalties: From 50 to 5,000 Euros for non-compliance with the rules concerning invoicing.

Best Practices

• Use certified PEPPOL access points to ensure that the transmission of electronic invoices is secure.
• Regularly update processes according to evolving governmental requirements.

B2C E-invoicing in Belgium

Here are the key features of B2C e-invoicing Belgium: 

Scope

• Not mandatory for B2C; businesses can adopt the issuance of e-invoices on a voluntary basis.

Key Considerations

• Though not a legal obligation, adopting e-invoicing for B2C transactions increases operational efficiency.
• It also increases digital adoption by customers and thereby their engagement and trust.

Best Practices

• Provide e-invoices as an option for customer convenience.
• Use the same structured format (Peppol-BIS) for consistency across operations.

Similarities and Differences in B2B, B2C, and B2G E-invoicing in Belgium

How Does E-Invoicing Work Under PEPPOL (Pan-European Public Procurement Online)? 

• It standardizes and facilitates cross-border and cross-platform exchange of e-invoices and allows seamless communication among the countries and service providers.
• It is based on a delivery network that operates through access points and certified providers for the secure exchange of invoices. 
• Developed the "4-Corner Model," which connects: 

C1: Supplier

C2: Supplier's e-invoicing service provider

C3: Customer's e-invoicing service provider

C4: Customer 

• Access Points provide the communication link between C2 and C3 for safe delivery of invoices. 
• This framework simplifies invoicing while ensuring standardisation and legal conformity.

Conclusion

The mandatory implementation of e-invoicing for the B2B and B2G sectors aims to improve Belgium’s stand in digital VAT compliance within European countries. The mandate highlights a critical shift in how businesses and public entities manage their invoicing, with structured electronic invoices being the legal standard.

While B2C transactions remain outside the ambit of e-invoicing for now, businesses should adopt best practices to future-proof their operations and ensure seamless compliance with the invoicing and VAT regulations.