Status of VAT modernization and e-invoicing

This objective focuses on the EU-wide introduction of electronic invoicing and electronic real-time reporting systems, with the aim of facilitating the automatic exchange of data between Member States. These measures are intended to increase transparency and reduce VAT fraud.

The implementation of this objective will be phased over time as follows:

From 2025:

• Member States may introduce mandatory electronic invoicing for domestic transactions without prior authorization from the European Commission, provided that such measures are limited to taxable persons established within their territory (see further below).

From 2026 – Specific rules for Belgium: Mandatory structured electronic invoicing (According to the Royal Decree published on 14 July 2025)

• Mandatory for B2B transactions

  As from 1 January 2026, all VAT taxable persons established in Belgium will be required to issue and receive structured electronic invoices for their (non-exempt) B2B transactions. This obligation also applies to fixed establishments of foreign VAT taxable persons located in Belgium but does not apply to foreign VAT taxable persons without a fixed establishment in Belgium.

• Peppol BIS as the mandatory format
  All structured electronic invoices must be exchanged via the Peppol network, in accordance with the European standard EN 16931. By mutual agreement, an alternative structured electronic format may be used, provided it also complies with this European standard. In practice, this means that by 2026, businesses must be technically capable of sending and receiving Peppol BIS e-invoices via the Peppol network. The use of PDF invoices will no longer be sufficient. The FPS Finance will publish a list of approved software solutions that meet these requirements.

• New fines
  In addition to the existing penalties for failing to comply with invoicing requirements (e.g., issuing invoices on time and correctly), new penalties will apply for non-compliance with the obligation to be technically capable of sending and receiving Peppol BIS e-invoices via the Peppol network. A fine of € 1.500 will be imposed for a first violation, € 3.000 for a second, and € 5.000 for a third.

• Probably from 2028 (limited) digital reporting in Belgium
  From 1 January 2028: Belgium will introduce near-real-time e-reporting for domestic transactions, replacing the current annual customer listing requirement.
   
• Rounding rules
  From 1 January 2026: Rounding will be permitted only on the total amount per VAT rate and will no longer be allowed at the individual line-item level.

• Electronic invoicing (in accordance with the European standard EN 16931) will be mandatory for cross-border B2B transactions within the EU.
• Intra-Community declarations will be replaced by a European central real-time reporting platform. Real-time reporting will be required to apply the VAT exemption for intra-Community supplies, and acquirers must report the acquisition within five days.
• National e-invoicing systems (except those established before 2024) must comply with the European standard.
• Invoices must be issued more promptly – within 10 days of the taxable event – and must include additional information, such as bank details.

From January 2035:

• National e-invoicing systems introduced before 2024 must also comply with the European standard.
  

However, the challenge remains that, at least until 2035, Member States will continue to use their own VAT reporting procedures. Each Member State may develop its own domestic real-time reporting (DRR) system, meaning that a fully standardized EU-wide system will not yet be in place.