Who has to use Peppol in Belgium, and who doesn’t?

The main rule: B2B between Belgian VAT-registered businesses

Since 1 January 2026, all Belgian VAT-registered businesses must use structured electronic invoices with each other: invoices that go straight from the supplier’s software to the customer’s. By default that happens over the Peppol network, in the Peppol BIS format. Another channel is only allowed if both parties agree and the invoice meets the European standard EN 16931.

So a PDF by email is no longer enough. You may still add a PDF or paper copy, but only the structured e-invoice is the legal invoice. What counts is when the invoice is drawn up: every invoice drawn up or sent since 1 January 2026 is covered, even for work done in 2025.

• If you have an active VAT number, the obligation applies to your business, whether you are a company, a sole trader or a non-profit with a VAT number.
• If one of the two parties isn’t VAT-registered, for example a non-profit without a VAT number, the obligation doesn’t apply to invoices between them.
• You can check for free in the Crossroads Bank for Enterprises (CBE) whether a business is VAT-registered: its capacities then show that it is subject to VAT, with the start date.
• You don’t need to ask your customers for a Peppol ID. Businesses registered on Peppol are listed on the network, and most invoicing software finds them by itself.
• Invoicing the government (B2G)? E-invoicing is already mandatory there for contracts published after 1 March 2024, as a rule from €3,000 excluding VAT. Federal contracting authorities require it below that amount too.

Private customers (B2C): no sending, but receiving

Invoices to private customers are not covered. A PDF, a paper invoice or a till receipt remain possible there. If you still want to invoice private customers over Peppol, they have to agree.

Watch out: if you buy from Belgian businesses yourself, you must be able to receive their e-invoices, even if you only sell to private customers. FPS Finance repeated this on 7 April 2026. Only businesses that issue no invoices to Belgian VAT-registered businesses and receive none from them are entirely outside the rule.

Private invoices you receive, such as gas and electricity at home, are not covered. If you want to claim part of them as a business expense, you can do so based on the paper or ordinary electronic invoice.

Foreign suppliers without a Belgian establishment (such as Microsoft Ireland)

A foreign business without a fixed establishment in Belgium is not covered by the obligation, even if it is registered for VAT in Belgium. It doesn’t have to send you an e-invoice over Peppol, and it doesn’t have to be able to receive one either. FPS Finance already applied that last point; since the law of 10 February 2026, published in the Belgian Official Gazette on 20 February 2026, the VAT Code says explicitly that such a business doesn’t have to be able to receive e-invoices, so you don’t have to send it one either.

Microsoft 365 is a typical example. According to Microsoft’s own tax information, Microsoft Ireland Operations Ltd. handles VAT for business customers in the EU. If you provide a valid VAT number, Microsoft invoices without VAT and, according to the same page, you might have to account for the VAT yourself. None of that involves Peppol: such an invoice can simply arrive by email and is valid.

• Keep that foreign PDF invoice and pass it to your bookkeeper, as before. You don’t need to demand an e-invoice.
• If you buy through a Belgian partner or reseller, that Belgian business invoices you, and its invoice does have to come as an e-invoice.
• If the foreign business has a fixed establishment in Belgium, the obligation does apply. Because you can’t always see that, a foreign business without a fixed establishment must tell its customers itself.
• A Belgian liable tax representative acting under its own Belgian VAT number is covered. If it uses the foreign business’s VAT number, or a number starting with BE0796.5 or BE0796.6, it isn’t.
• Peppol can also be used internationally if both parties want to: registering on Peppol counts as agreeing to receive e-invoices. For invoices between EU member states, e-invoicing becomes mandatory from 2030, FPS Finance announces.

Till receipts and hospitality

A till receipt is not an invoice. If your customer is a VAT-registered business or a legal entity, you must always issue an invoice as well as the receipt from your registered cash register system (GKS/SCE, the ‘white till’). FPS Finance confirms that the e-invoicing obligation doesn’t change this. The other way round, an invoice never replaces the cash register receipt.

In practice: a private guest who comes to eat gets the cash register receipt, as before. A Belgian business that wants an invoice for a business lunch, a reception or a catering order gets the receipt and a structured e-invoice over Peppol.

• Record that invoice in your sales invoice book and deduct the transaction from the cash register turnover in your VAT return, so it isn’t counted twice.
• As a restaurant or café, you also receive the invoices of your Belgian suppliers, such as the drinks merchant or the wholesaler, as e-invoices.
• Simplified invoices (Article 13 of Royal Decree No. 1) are still allowed, but they too go at least in the Peppol BIS format.
• If your business buys something at a till, the till receipt is not an invoice. To deduct VAT you need a regular invoice; if the purchase falls under the obligation, that is a structured e-invoice. FPS Finance allows an exception if the substantive conditions are met (‘substance over form’).

Small businesses with the VAT exemption: receiving too

If you use the small-business VAT exemption scheme (annual turnover up to €25,000), you are in principle covered by the obligation. FPS Finance issued a clarification on 7 April 2026 to avoid misunderstandings after media reports.

That means two things. You must be able to receive e-invoices from your Belgian suppliers. And your invoices to Belgian VAT-registered customers must be e-invoices, with the legal exemption wording on them. If you only sell to private customers, only receiving remains.

The other exceptions

Apart from foreign businesses without a Belgian establishment, there are only a few exceptions:

• Bankrupt VAT-registered businesses don’t have to send e-invoices.
• Flat-rate taxable persons (Article 56 of the VAT Code) don’t have to send e-invoices, but must be able to receive them. That scheme ends on 1 January 2028 at the latest.
• Farmers under the special agricultural scheme don’t issue invoices for that activity, but must be able to receive e-invoices. Their customer issues the purchase statement, since 1 January 2026 in structured electronic form.
• Businesses that only carry out transactions exempted by Article 44 don’t have to send or be able to receive. A transaction exempted by Article 44 is outside the obligation for everyone.
• If your customer can’t receive an e-invoice for technical reasons, since 20 February 2026 you as the supplier don’t have to send one. You then issue an ordinary invoice, on paper or as a PDF. Your customer remains obliged to be able to receive e-invoices.

Know where you stand in five minutes

No need to panic. With these steps you know whether the obligation applies to you and whether you’re ready:

1. 1Check in the CBE whether your business is listed as subject to VAT. If so, the obligation applies in principle, unless you fall under one of the exceptions above.
2. 2Check with the free Peppol check on this page whether you can receive e-invoices under 0208, your enterprise number, and under 9925, your VAT number. Not found? Ask your accounting software or Peppol provider to register you.
3. 3Go through your customers: to Belgian VAT-registered businesses, every invoice goes as an e-invoice. To private and foreign customers, you can carry on as before.
4. 4Go through your suppliers: Belgian suppliers send you e-invoices. Foreign suppliers without a Belgian establishment, such as Microsoft Ireland, may keep sending a PDF.
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.

Read next

• Belgian small-business VAT exemption on Peppol: fix BR-E-10 and the VAT codeUnder the exemption scheme you charge no VAT, but your Peppol invoice still needs a VAT category. Use category E (exempt) at 0% and put the statutory wording “Bijzondere vrijstellingsregeling van belasting” (French: “Régime particulier de la franchise de taxe”) as exemption reason (BT-120). Without that reason the invoice fails BR-E-10.Read more
• Peppol e-invoicing fines in Belgium: what you actually riskBelgian 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.Read more
• Customer not on Peppol: how do you send your invoice?First make sure your customer really isn’t on Peppol: check both the enterprise number (0208) and the VAT number (9925). If they can’t be reached under either, the Belgian federal FAQ lets you issue the invoice another way, for example on paper, or as a PDF if your customer agrees. That invoice is legally valid.Read more
• Supplier invoices never arrive on Peppol? Check 0208 and 9925When a supplier invoice never arrives, the supplier is almost always sending it to a Peppol ID you aren’t registered under: to 9925 (your VAT number) while you can only be reached under 0208 (your enterprise number), or the other way round. Peppol treats them as two separate addresses, so the invoice is never delivered and you get no message. InvoiceVerify’s live check below shows in seconds under which ID a company receives invoices.Read more

Frequently asked questions

Do I have to use Peppol if I only sell to private customers?

Not for your invoices to private customers. But if you buy from Belgian businesses, you must be able to receive their e-invoices, 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 rule.

Why doesn’t my Microsoft Ireland invoice come over Peppol?

Because Microsoft Ireland Operations Ltd. isn’t established in Belgium. Foreign businesses without a fixed establishment in Belgium aren’t covered by the obligation, even with a Belgian VAT number, FPS Finance explains. Their PDF invoice is valid: keep it and pass it to your bookkeeper as before.

Does a small business with the VAT exemption have to be able to receive e-invoices?

Yes. Businesses under the small-business exemption scheme (turnover up to €25,000) are in principle covered: they must be able to receive e-invoices, and their invoices to Belgian VAT-registered businesses must be e-invoices. Only businesses that exclusively carry out transactions exempted by Article 44, such as a doctor for exempt medical care, are outside the rule.

Is a till receipt enough if my customer is a business?

No. If your customer is a VAT-registered business or a legal entity, you issue an invoice as well as the cash register receipt, and to a Belgian VAT-registered business that has been an e-invoice since 1 January 2026. The receipt stays mandatory; the invoice doesn’t replace it.

Does the obligation apply to a foreign company with a Belgian VAT number?

Not if it has no fixed establishment in Belgium: then it doesn’t have to send or receive e-invoices. If it does have a fixed establishment in Belgium, the obligation applies to that establishment’s transactions. The foreign business must tell its customers itself which case applies.

How do I know whether my company can already 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. FPS Finance: General questions on the B2B obligation (questions 2, 11, 14, 15 and 16; checked on 5 November 2026)
2. FPS Finance: Specific questions about e-invoicing (questions 15, 18, 24 and 25)
3. FPS Finance: Voor wie wordt e-facturatie verplicht? (who is covered, in Dutch; checked on 5 November 2026) — 9 October 2024
4. FPS Finance: End of the general tolerance period for e-invoicing (in Dutch) — 7 April 2026
5. Law of 6 February 2024 introducing the e-invoicing obligation (Belgian Official Gazette, Justel, in French) — 20 February 2024
6. Law of 10 February 2026 on various VAT provisions, Article 4 (Belgian Official Gazette, Justel, in French) — 20 February 2026
7. FPS Finance: Circular 2026/C/43 on the law of 10 February 2026, sections 2 and 6 (text on Juriel, in Dutch) — 18 March 2026
8. FPS Finance: Can an invoice replace the cash register receipt? (registered cash register website, in Dutch) — 16 December 2014
9. FPS Finance: Can I also use e-invoicing outside Belgium, internationally? — 9 October 2024
10. Microsoft Learn: Tax information for Microsoft 365 for business products and services
11. Reddit r/BEFreelance: “Peppol from Microsoft” (user report) — 4 January 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.