Peppol e-invoicing fines in Belgium: what you actually risk

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Situation on

Belgian law sets €1,500 for a first infringement, €3,000 for a second and €5,000 for each further one if your business can’t send and receive structured e-invoices. The general tolerance period ended on 31 March 2026. As HLN reported on 3 August 2026, FPS Finance had not issued a single fine by then and preferred dialogue. Check for free on this page whether your company can be reached on Peppol.

The amounts: €1,500, €3,000 and €5,000

First infringement
€1,500
Second infringement
€3,000
at least three months after the previous finding
Each further infringement
€5,000

Since 1 January 2026, every Belgian VAT-registered business that falls under the obligation must have the technical means to issue and receive structured e-invoices. The Royal Decree of 8 July 2025, published in the Belgian Official Gazette on 14 July 2025, attaches fixed fines to that.

An infringement only counts as a second or further one if the administration establishes it at least three months after the previous infringement that led to a fine. So there are at least three months between two findings that can lead to a higher fine.

  • What is fined is not having the technical means to send and receive e-invoices. The decree sets no amount per invoice.
  • Sending and receiving both count. If you can send but not receive, you are not compliant.
  • Other invoicing failures, such as issuing no invoice, a late one or an incorrect one, stay under the existing fine scales. The decree added no new amounts for them.

The tolerance period is over

From 1 January to 31 March 2026, FPS Finance did not fine breaches of the new obligation, provided the business could show it had taken timely and reasonable steps. Invoices still had to be issued another way during that period.

On 7 April 2026, FPS Finance confirmed that this general tolerance has ended. For self-billing, a targeted tolerance applied until 30 June 2026 inclusive, where the software supplier was still building the feature. That date has passed too.

A technical problem outside your control?

According to the same notice of 7 April 2026, FPS Finance can still decide not to fine in exceptional circumstances. That is not automatic: it follows an individual analysis of your case. You can submit your situation through the contact form on the official e-invoicing website.

Have any fines been issued?

On 3 August 2026, HLN reported, based on the Belga news agency, that FPS Finance had not yet fined any business that wasn’t connected to Peppol. A spokesperson said so. The administration preferred a “constructive dialogue”, which had made fines unnecessary so far. The Brussels Times carried the same report in English.

According to the same report, 89% of Belgian VAT-registered businesses, or 1,059,335 companies, used Peppol by mid-July. FPS Finance estimated that at most 1%, around 12,000 business owners, still had to join; some VAT-registered businesses don’t trade with other businesses at all.

We checked again on 4 November 2026. The most recent notice on the FPS Finance e-invoicing news page was still the one of 7 April 2026, and we found no later official figures or reports of fines being issued.

What we know and what we don’t

That no fines had been issued is what FPS Finance told the press on 3 August 2026. It doesn’t prove that no fine has been issued since, and it doesn’t mean the rules don’t apply: the amounts are in the law and the tolerance period is over. The date at the top of this page shows when we last checked the sources.

Does the obligation apply to you?

FPS Finance clarified on 7 April 2026 who is covered:

  • Businesses under the small-business VAT exemption scheme are in principle covered too.
  • You only invoice private customers but buy from Belgian businesses? Then you must be able to receive e-invoices from your suppliers.
  • If you issue no invoices to Belgian VAT-registered businesses and receive none from them, the obligation does not apply.

What you can do today

No need to panic: with these steps you quickly know where you stand, and you have proof if questions come up.

  1. 1Check your company with the free Peppol check on this page. You see straight away whether you can receive invoices under 0208, your enterprise number, and under 9925, your VAT number.
  2. 2Not found under 0208? Ask your Peppol provider or accounting software to register your enterprise number. If you also register under 9925, invoices from suppliers who address your VAT number arrive too.
  3. 3Test sending as well: send an invoice to a customer over Peppol and check that it arrives. The check only shows whether you can receive; sending depends on your software.
  4. 4Keep proof of your steps: the contract with your provider, dates and support tickets. If something goes wrong that is outside your control, submit your case through the FPS Finance contact form.
  5. 5Bookkeeper? Check all your clients under 0208 and 9925 in one go with the free client-list check. The first 10 companies of every list are free; full lists are part of Pro, which is coming soon — join the waitlist for early-bird pricing.

If your customer or supplier isn’t ready

According to the official FAQ, a customer who can’t receive structured e-invoices risks a penalty themselves. You may then invoice them another way, for example on paper, or as a PDF if your customer agrees. That invoice is legally valid and fulfils your own invoicing obligation.

If your supplier isn’t ready, you keep your right to deduct VAT based on the invoice they issue another way.

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Frequently asked questions

Is the fine charged per invoice?
No. The Royal Decree fines not having the technical means to send and receive e-invoices: €1,500 for a first infringement, €3,000 for a second and €5,000 for each further one. It sets no amount per invoice. The existing fines for missing, late or incorrect invoices still apply.
Have any Peppol fines been issued yet?
Not as of 3 August 2026, according to HLN (Belga): FPS Finance preferred a constructive dialogue. On 4 November 2026 we found no later official figures. That is no guarantee for the future: the fines are in the law and the tolerance period is over.
I’m connected, but my software doesn’t work properly. Do I risk a fine?
FPS Finance can decide not to fine in exceptional circumstances, after an individual analysis of your case. That isn’t automatic. Keep proof of your steps and submit your situation through the contact form on the official e-invoicing website.
I use the small-business VAT exemption. Must I be able to receive too?
In principle yes, FPS Finance confirmed on 7 April 2026. Only businesses that issue no invoices to Belgian VAT-registered businesses and receive none from them are outside the obligation.
How do I know whether I can receive e-invoices?
Use the free Peppol check on this page: enter your enterprise or VAT number and you see live whether you can be reached under 0208 and 9925. Whether you can send depends on your software; send a test invoice or ask your provider.

Sources

  1. Royal Decree of 8 July 2025 (Belgian Official Gazette, Justel, in French) —
  2. FPS Finance: Period of tolerance during the first three months of 2026 —
  3. FPS Finance: End of the general tolerance period for e-invoicing (in Dutch) —
  4. FPS Finance: General questions on the B2B obligation (questions 7 and 8)
  5. HLN (Belga): “Nog geen boetes voor bedrijven die niet aangesloten zijn op Peppol” (in Dutch) —
  6. The Brussels Times (Belga): “Companies not yet fined for not joining Peppol e-invoice network” —
  7. FPS Finance: e-invoicing news (in Dutch; checked on 4 November 2026, latest notice 7 April 2026)

This page summarises the law and official FPS Finance guidance, and reports press coverage where it says so. It is not legal or tax advice — check with your accountant or adviser for your situation.

Free check

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Enter your enterprise or VAT number in the free Peppol check. You see live whether your company can receive invoices under 0208 and 9925, and what to do if it can’t.

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