Belgium has rolled out a series of e-invoicing mandates, first requiring businesses to submit structured e-invoices when dealing with public sector entities and soon expanding to B2B transactions from January 2026. These mandates rely on compliance with the EN 16931 standard, ensuring that invoices follow a common, machine-readable structure that both sender and receiver systems can understand without human intervention.
In this article, we’ll explore EN 16931, why it matters for Belgium’s digital economy, how it works in practice, and what businesses need to know to stay compliant and competitive in this new era of standardized e-invoicing.
As businesses and governments worldwide move towards digital transformation, electronic invoicing (e-invoicing) has become a cornerstone of modern financial operations. Unlike traditional paper or PDF invoices, e-invoices are structured digital documents that can be automatically generated, transmitted, received, and processed by accounting systems — dramatically improving efficiency, accuracy, and speed. By replacing manual data entry with seamless machine-to-machine communication, e-invoicing reduces costs, minimizes errors, and supports faster payments.
Recognizing these advantages, the European Union took a major step by introducing legislation to promote standardized e-invoicing across member states, particularly in public procurement. A key result of this effort is the EN 16931 standard a European framework that defines the essential data elements of an electronic invoice and ensures interoperability between different businesses and public authorities across borders.
EN 16931 is the official European standard for electronic invoicing. (EN stands for “European Norm.”) It was published in 2017 by the European Committee for Standardization (CEN) to harmonize e-invoices across Europe. The full title is “Electronic invoicing – Semantic data model of the core elements of an electronic invoice.”
Simply put, EN 16931 defines:
EN 16931 was developed in response to the EU Directive 2014/55/EU, which required all public authorities in EU member states to:
At the heart of EN 16931 is the core invoice model — a standardized list of all essential pieces of information that ensures the fundamental business data in any invoice remains consistent, complete, and interoperable across different systems and countries. such as:
EN 16931 is often referred to as a semantic standard because it focuses on:
This approach allows flexibility in how the data is technically implemented, while still ensuring that everyone interprets the information the same way.
Although EN 16931 defines the content and meaning, it must be implemented through specific technical formats (also known as syntaxes). The two primary approved formats are:
These formats structure the invoice data according to EN 16931’s rules, enabling automated processing by IT systems.
Thanks to EN 16931 all EU countries now use a common invoice language for public procurement and Cross-border interoperability has dramatically improved.
Businesses can send structured invoices across Europe without worrying about national format differences, simplifying public sector transactions and reducing administrative burdens.
EN 16931 is not merely a bureaucratic checkbox. It serves as a foundation for many e-invoicing systems and networks. For instance, the Peppol network an international e-invoicing infrastructure builds its invoice format to comply with EN 16931. This broad adoption means EN 16931 is a critical pillar in building unified, efficient, and digital trade ecosystems across Europe and increasingly, worldwide.
Feature | Description |
Core Data Model | Specifies required invoice fields: supplier/customer info, line items, totals, VAT, payment terms |
Machine-Readable Format | Typically uses XML, enabling automated processing |
Harmonization | Reduces complexity and errors, facilitating cross-border and cross-platform invoicing |
Customization (CIUS) | Allows countries to adapt the core standard for local requirements (e.g., Peppol BIS) |
Suppose a small business in Belgium needs to send an invoice to a government agency. Here's how the process might work step by step:
Explanation:
Throughout this process, EN 16931 is the common language that both the supplier’s and buyer’s systems understand, while Peppol (in this example) is like the delivery infrastructure. The result is a smooth, fast transaction: the invoice goes from the supplier’s computer to the buyer’s system without any manual intervention.
In real life, this means invoices get paid faster and with fewer mistakes. For instance, Belgium’s Mercurius platform (which uses EN 16931-compliant formats) even offers a feature to convert the data into a PDF for human readability if needed=, ensuring that even parties without advanced software can review the content. But the key is that in the background, the data remains standardized and machine-readable.
This simple example shows how EN 16931 makes e-invoicing efficient: senders don’t have to worry about each customer’s format requirements, and receivers can process many invoices automatically, saving time and money.
What does an EN 16931 e-invoice look like (in terms of information included)? At a high level, it contains all the details you would expect on a standard invoice, but organized in a structured way.
The standard defines a set of data fields and groups that cover the necessary invoice information. Here are the key components of an EN 16931-compliant invoice:
All these components are defined in EN 16931’s semantic data model. In fact, the standard defines hundreds of specific data fields to cover various scenarios and business needs (many fields are optional or conditional).
For example, EN 16931 includes elements for things like the buyer’s purchase order reference, the delivery address (if different from the billing address), or an allowance on the whole invoice (like a 5% discount on the total). Each field has a defined meaning and format – for instance, dates must be in a certain format (YYYY-MM-DD) and amounts must clearly indicate their currency. By specifying these details, EN 16931 ensures that whether an invoice is issued in Belgium, France, or any other country, the core information is structured the same way and carries the same meaning.
This comprehensive structure covers everything needed for legal and tax compliance as well. (For instance, EU VAT laws require certain info on invoices; EN 16931 makes sure all those elements are present and labeled.)
EN 16931 compliance means your e-invoice is complete, correctly structured, validated, and universally readable by any compliant system in the EU. Most businesses achieve this by using certified e-invoicing software that automatically applies all the required rules and checks.
To comply with the EN 16931 standard for electronic invoicing, both the e-invoice and the systems that create or receive it must meet the following essential requirements:
Requirement | What It Means in Practice |
1. Include All Core Information | The e-invoice must contain all essential data fields: seller and buyer details, invoice number and date, item descriptions, prices, tax rates/amounts, and totals. This ensures the invoice is complete and legally valid. |
2. Use a Structured Format | The invoice must be in a machine-readable, structured format (usually XML) that follows the EN 16931 data model and uses standard code lists (e.g., ISO country/currency codes). This guarantees consistency and interoperability. |
3. Accuracy and Validations | All mandatory fields must be present, calculations must be correct, and data must follow the prescribed formats and codes. The invoice must pass validation checks to ensure internal consistency and reliability. |
4. Sender & Receiver Compliance | Both the sender and receiver must support EN 16931. The issuer must create compliant invoices, and the receiver’s system must be able to accept and process them, ensuring full interoperability. |
5. Compatibility of Customizations (CIUS/Extensions) | Any country- or sector-specific adaptations (CIUS or extensions) must remain compatible with the core EN 16931 standard, so invoices remain readable and processable by all compliant systems. |
EN 16931 compliance brings significant advantages for businesses and public entities adopting standardized electronic invoicing across the EU:
EN 16931 is a key standard in Europe, but e-invoicing is a global trend and there are other standards and frameworks out there. Below is a simple comparison between EN 16931 and some major e-invoicing standards or models worldwide, to put things in perspective:
Standard/Framework | Scope/Origin | Description & Key Features |
EN 16931 | Europe (CEN) | Defines the core data model for e-invoices, focusing on the semantic content (fields, meanings). Mandated for EU public procurement and increasingly for B2B. Implemented via XML formats like UBL and CII. Ensures interoperability across EU systems. |
Peppol (BIS & Network) | International (EU origin) | A global interoperability network and set of specifications. Uses Peppol BIS Billing 3.0, fully compliant with EN 16931. Provides a secure network of Access Points for exchanging invoices. Widely used in Europe, Asia-Pacific, and beyond. |
OASIS UBL | International (OASIS) | XML-based standard for business documents. Used as a primary syntax for EN 16931. Open, royalty-free, supports multiple languages and currencies. Adopted globally in various e-invoicing systems. |
EDIFACT | International (UN/CEFACT) | Legacy EDI standard using text segments. Includes the INVOIC message format. Still used in supply chains and logistics, but less human-readable and more complex than XML standards. Preceded XML-based standards like EN 16931 and UBL. |
Country-Specific (e.g., CFDI, NF-e) | Latin America, others | Local government-defined XML invoice standards (e.g., Mexico’s CFDI, Brazil’s NF-e). Typically use “clearance” models where tax authorities pre-approve each invoice. Unique to each country’s legal requirements. |
Belgium implemented the EU Directive 2014/55/EU, requiring public authorities to accept e-invoices in the EN 16931 format since 2019. This ensures all invoices sent to Belgian government entities must comply with the European standard.
Here’s an overview of Belgium’s e-invoicing mandate and how EN 16931 fits in:
The EN 16931 Electronic Invoicing Standard plays a foundational role in Europe's drive toward seamless, efficient, and interoperable digital invoicing. By defining a common data model for e-invoices, EN 16931 ensures that invoices can be exchanged and understood across different systems and countries without manual intervention. In Belgium, this standard underpins both public sector (B2G) e-invoicing requirements and the country’s upcoming B2B e-invoicing mandate, making it essential for businesses to align with EN 16931 to remain compliant, competitive, and digitally agile. The standard’s structured format, focus on automation, and compatibility with delivery networks like Peppol help companies streamline their billing processes, reduce errors, lower costs, and speed up payment cycles.
As Belgium advances its digital agenda, EN 16931 compliance is becoming not just a regulatory necessity but a strategic advantage. Businesses that adopt this standard benefit from easier cross-border trade, enhanced operational efficiency, and better integration with public and private partners.