InvoiceVerify

Peppol for Belgian freelancers: what still goes wrong after you pick a tool

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Since 1 January 2026, freelancers and small businesses with a Belgian VAT number also send their invoices to Belgian businesses over Peppol, including under the small-business VAT exemption. Picking a tool is only the first step: what goes wrong after that almost always comes down to the customer’s Peppol ID, an error code such as BR-CO-15, the VAT wording or a credit note. Below, for each problem: what you see, why it happens and how to fix it.

What the obligation means for you as a freelancer

If you have an active Belgian VAT number, the obligation applies to you, whether freelancing is your main job or a side business, and also under the small-business VAT exemption. Invoices to Belgian VAT-registered customers go out as structured e-invoices, in practice over Peppol. And you must be able to receive e-invoices from your Belgian suppliers.

Invoices to private persons fall outside the obligation, and for customers abroad Peppol is voluntary. If you’re unsure whether it applies to you at all, start with the overview of who must use Peppol.

1. Your customer can’t be found on Peppol

What you see
Your tool says “receiver not found”, “not registered” or “no SMP entry”, or won’t let you pick the customer as a Peppol receiver.
Why it happens
Your customer isn’t on Peppol under the ID your tool tries, or isn’t registered anywhere yet. Many tools look under one ID only, while a Belgian company can be registered under its enterprise number (0208), its VAT number (9925) or both.
The fix
Look your customer up under both 0208 and 9925. If they receive under either, put that ID in the customer record and send again. If they’re not registered at all, the official FAQ lets you issue the invoice another way: on paper, or as a PDF if your customer agrees. That invoice is valid; once they can receive, new invoices go over Peppol.

Full fix and tools

2. Wrong Peppol ID: enterprise number (0208) or VAT number (9925)

What you see
Your customer says they’re on Peppol, but your invoice doesn’t arrive. Or your access point stops it with an EndpointID error such as BR-62 or PEPPOL-COMMON-R043.
Why it happens
In Belgium every company should be registered on Peppol at least under its enterprise number, scheme 0208; the VAT number, scheme 9925, can be added. An ID with the wrong scheme, “BE” in front of a 0208 number or a single wrong digit points to a receiver that doesn’t exist.
The fix
Use 0208 with the ten digits of the enterprise (KBO/BCE) number without BE, or 9925 with the VAT number including BE, and pick the ID your customer receives invoices under. Put it in your tool’s customer record so every later invoice gets the right address.

Full fix and tools

Correct: the Peppol address of a Belgian customer under 0208 (under 9925: BE0403170701)
<cac:AccountingCustomerParty>
  <cac:Party>
    <cbc:EndpointID schemeID="0208">0403170701</cbc:EndpointID>
    …
  </cac:Party>
</cac:AccountingCustomerParty>

3. Invoice rejected with a BR code

What you see
Your tool or access point reports a code such as BR-CO-15, PEPPOL-EN16931-R003 or BR-S-08, and the invoice doesn’t go out.
Why it happens
The access point checks every invoice against the EN 16931 and Peppol BIS Billing 3.0 rules before sending it. The code tells you which rule failed: BR-CO-15 means the total with VAT isn’t the total without VAT plus the VAT, PEPPOL-EN16931-R003 that there’s neither a buyer reference nor an order number.
The fix
Look the code up: every error code has a page with the cause and the fix. Correct the invoice in your tool, often by adding a reference or fixing rounding per line, then check the XML again. If it was stopped before delivery, your customer received nothing: send the corrected version without booking it a second time.

Full fix and tools

4. VAT exemption wording missing or out of date

What you see
You invoice under the small-business VAT exemption and the invoice fails BR-E-10, or your template still says the pre-2025 wording (“Bijzondere vrijstellingsregeling kleine ondernemingen”).
Why it happens
Even without VAT, a Peppol invoice needs a VAT category and an exemption reason. Since 1 January 2025, article 5 §1 10°quater of Royal Decree no. 1 requires the wording “Bijzondere vrijstellingsregeling van belasting” (Dutch) or “Régime particulier de la franchise de taxe” (French). Older templates still use the earlier text, and some tools leave the reason empty.
The fix
Put the lines in VAT category E at 0%, enter the legal wording as the exemption reason (BT-120), leave the code empty and keep your VAT number on the invoice. Don’t use category O: it isn’t allowed together with your VAT number (BR-O-02).

Full fix and tools

Correct: VAT breakdown under the small-business exemption
<cac:TaxSubtotal>
  <cbc:TaxableAmount currencyID="EUR">800.00</cbc:TaxableAmount>
  <cbc:TaxAmount currencyID="EUR">0.00</cbc:TaxAmount>
  <cac:TaxCategory>
    <cbc:ID>E</cbc:ID>
    <cbc:Percent>0</cbc:Percent>
    <cbc:TaxExemptionReason>Bijzondere vrijstellingsregeling van belasting</cbc:TaxExemptionReason>
    <cac:TaxScheme><cbc:ID>VAT</cbc:ID></cac:TaxScheme>
  </cac:TaxCategory>
</cac:TaxSubtotal>

5. Credit notes

What you see
Your credit note is rejected with PEPPOL-EN16931-P0100 or BR-55, or you still make it as a PDF although the invoice went over Peppol.
Why it happens
According to the official FAQ, a credit note that changes a Peppol invoice and refers to it unambiguously is itself a structured e-invoice, issued in the same format. An Invoice document with type 381, or a reference without an invoice number, fails validation.
The fix
Send it over Peppol as a separate CreditNote document with type 381 and positive amounts. Reference the number and date of the original invoice in BillingReference, and use the same VAT category as the lines you credit.

Full fix and tools

6. Invoices to private persons

What you see
Your tool asks for a Peppol ID for a customer without a VAT number, or an invoice to a private person gets stuck.
Why it happens
Private persons aren’t on Peppol, and invoices to private persons aren’t covered by the obligation.
The fix
Mark the customer as a private person, without a VAT number, in your tool and send the invoice as before: as a PDF or on paper. Invoicing a private person over Peppol is only possible with their agreement. If you only work for private persons, you must still be able to receive e-invoices from your Belgian suppliers.

Full fix and tools

7. Customers abroad

What you see
Your tool can’t find your customer in the Netherlands, France or Germany on Peppol, or suggests sending a PDF instead.
Why it happens
The Belgian obligation covers invoices between VAT-registered businesses established in Belgium. For a customer abroad, Peppol is voluntary: it works if you both choose it, and registering on Peppol counts as agreeing to receive that way.
The fix
Look your customer up in the Peppol Directory. If they’re listed, you can invoice them over Peppol. If not, send your invoice as before. Peppol doesn’t change the VAT rules for foreign customers; if you’re unsure about the VAT wording, ask your accountant.

Full fix and tools

Check your first invoice before you send it

A few minutes up front save you a rejected invoice and a customer on the phone. How to handle your first Peppol invoice:

  1. 1Look your customer up under 0208 and 9925 and put the ID that receives invoices in the customer record.
  2. 2Ask your customer which reference or order number they expect on the invoice, and fill it in (PEPPOL-EN16931-R003).
  3. 3Under the small-business exemption: category E, 0% and the legal wording as the exemption reason.
  4. 4Download the UBL XML from your tool, if it allows that, and drop it into the free checker on this page. You see every rule it breaks, with the line number. Without an account you get 3 checks a month; the sample file is always free.
  5. 5Only then send it, and check in your tool the next day that the invoice shows as delivered.

What the checker does and doesn’t tell you

The checker tests your XML against the EN 16931 and Peppol BIS Billing 3.0 rules InvoiceVerify runs: a strong signal, not an official validation. Whether your customer can receive under that ID is what the Peppol ID lookup shows.

Check your first invoice

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Frequently asked questions

Do I have to use Peppol if freelancing is my side business?
Yes, if you have an active Belgian VAT number and invoice Belgian VAT-registered customers. The obligation depends on your VAT number, not on whether it’s your main or side business, and the small-business VAT exemption doesn’t take you out of it.
I already have a Peppol tool. Why is my invoice still rejected?
Your tool sends what you enter. Most rejections come from the content: neither a buyer reference nor an order number (PEPPOL-EN16931-R003), totals that don’t add up (BR-CO-15), an exemption without a reason (BR-E-10) or a wrong Peppol ID for your customer.
My customer isn’t on Peppol. Am I at fault?
According to the official FAQ, you meet your invoicing obligation if you issue the invoice another way, for example on paper or as a PDF your customer agrees to. The risk of a penalty lies with the customer who can’t receive. Note when you checked both IDs.
Do invoices to private persons have to go over Peppol?
No. Invoices to private persons fall outside the obligation; a PDF or paper invoice is still fine. You do have to be able to receive e-invoices from your Belgian suppliers.
What wording goes on an invoice under the small-business exemption?
Since 1 January 2025: “Bijzondere vrijstellingsregeling van belasting” in Dutch or “Régime particulier de la franchise de taxe” in French. On Peppol that text is the exemption reason (BT-120) with VAT category E.
Is InvoiceVerify an official Peppol validator?
No. InvoiceVerify is an independent tool made by Kalmwerk, not linked to the government or to OpenPeppol. The checker is a strong signal, not an official validation; the rules on this page come from the sources below.

Sources

  1. FPS Finance: Who will e-invoicing become mandatory for? (in Dutch; checked on 14 November 2026) —
  2. FPS Finance: General questions on the B2B obligation (customer can’t receive, other ways to issue; checked on 14 November 2026)
  3. FPS Finance: Specific questions about e-invoicing (credit notes, exemption reason in BT-120; checked on 14 November 2026)
  4. FPS Finance: General questions about Peppol (registration under the enterprise number, 0208; checked on 14 November 2026)
  5. FPS Finance: Can I also use e-invoicing outside Belgium? (checked on 14 November 2026)
  6. FPS Finance: VAT exemption scheme for small businesses (in Dutch; checked on 14 November 2026)
  7. Royal Decree no. 1 on VAT, article 5 §1 10°quater (Justel, in Dutch; checked on 14 November 2026)
  8. OpenPeppol: Peppol BIS Billing 3.0 (checked on 14 November 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.

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