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Spotlight PEPPOL BIS Billing 3.0 The EU e-invoicing mandate is here — France Sept 2026, Belgium Jan 2026, Germany 2025.

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Royal Decree of 20 March 2025 — mandatory B2B e-invoicing in Belgium

Published in the Moniteur belge / Belgisch Staatsblad on 31 March 2025, the Royal Decree of 20 March 2025 makes structured electronic invoicing mandatory for all operations between Belgian VAT-registered businesses from 1 January 2026, with PEPPOL-BIS Billing 3.0 as the sole permitted format.

Genesis: from ViDA directive to Belgian text

Belgium deliberately anticipates the European ViDA directive (VAT in the Digital Age, formally Council Directive (EU) 2025/516 of 11 March 2025), which generalises B2B intra-EU e-invoicing by 2030. The trajectory is as follows:

  • 2014-2018 — Mercurius B2G phase. Transposition of Directive 2014/55/EU by the Royal Decree of 9 March 2017; Mercurius becomes mandatory for any federal public procurement contract above EUR 30,000 excl. VAT. The Brussels and Walloon Regions follow within their respective scope.
  • 2022 — ViDA-anticipation action plan. Finance Minister Vincent Van Peteghem announces in the 2022-2024 general policy note the project to extend the obligation to all domestic B2B from 1 January 2026.
  • March 2024 — Royal Decree draft. Consultation with professional federations (FEB / VBO, UCM, Unizo, Boerenbond, Federgon). Adoption of the principle of exclusive use of PEPPOL-BIS 3.0 to avoid the fragmentation observed in Italy (SdI) and France (PPF/PDP).
  • 17 March 2025 — Council of Ministers. The draft is approved in restricted council with the green light from the Council of State legislation section (opinion 75.937/2 of 7 March 2025).
  • 20 March 2025 — Royal signature. The decree is signed by King Philippe upon proposal by the Minister of Finance and the Minister of Economy.
  • 31 March 2025 — Official publication. Moniteur belge / Belgisch Staatsblad edition 2 — the constitutional 10-day delay is respected, with deferred entry into force on 1 January 2026.

The Royal Decree finds its enabling basis in the Belgian VAT Code, specifically articles 53 (invoices and records) and 53 §2bis (electronic invoicing). This paragraph, introduced by the Act of 27 June 2022, authorises the King to impose a particular structured format without requiring formal legislation.

The text also amends Royal Decree No. 1 of 29 December 1992 on measures to ensure the payment of VAT, by inserting a new chapter III bis "Structured electronic invoices" (new articles 14ter to 14quinquies).

text extract-art-1-RD-20-march-2025.txt 
Art. 1. § 1. From 1 January 2026, taxable persons identified for VAT in
Belgium shall issue and receive invoices relating to their B2B operations
in the form of structured electronic invoices compliant with European
standard EN 16931 and the PEPPOL BIS Billing 3.0 profile.

§ 2. Invoices shall be transmitted via the PEPPOL network, provided that
the issuing and receiving parties have a PEPPOL access point registered
in the Service Metadata Locator (SML) of the European Union.

§ 3. The obligations set out in § 1 apply without prejudice to the right
of the parties to agree on an alternative structured format, provided
that it complies with standard EN 16931 and ensures technical and
semantic interoperability.

Scope: who is concerned

The decree applies to any taxable person identified for VAT in Belgium, i.e. holding a valid BTW-BE or TVA-BE number. This covers approximately 1,100,000 businesses according to the KBO/BCE registry (Crossroads Bank for Enterprises) as of 1 January 2025.

  • Mandatory issuance: as soon as an operation is carried out between two Belgian taxable persons (domestic B2B), the invoice must be issued in structured format.
  • Mandatory reception: any VAT-registered taxable person must be able to receive a valid PEPPOL-BIS 3.0 invoice. A recipient who refuses a compliant invoice commits a fault (new art. 14quater).
  • Foreign companies with BTW-BE number: included as soon as they invoice a Belgian customer. The real seat has no effect on the obligation.
  • Holdings and SPVs: included if they issue or receive B2B invoices in the VAT sense.

Exclusions and exceptions

The text leaves several categories of operations out of scope:

  • B2C — Sales to individuals. Out of scope. Cash receipts, e-receipts and invoices to non-taxable persons remain on pre-existing formats (paper, unstructured PDF, POS ticket).
  • Cross-border operations. Intra-EU B2B flows and flows with third countries remain governed by the classical rules until the entry into force of ViDA e-reporting (1 July 2030 planned).
  • Strict VAT exemptions. Small enterprises benefiting from the franchise regime (turnover < EUR 25,000 excl. VAT/year, art. 56bis VAT Code) are exempt from issuance but must still be able to receive.
  • Art. 44 VAT Code exemptions. Medical professions, education, certain cultural activities. Out of scope for exempt operations, but in scope for their ancillary taxable operations.
  • Operations in bankruptcy or judicial reorganisation. Suspended until resumption of activity.

Mandatory format: PEPPOL-BIS 3.0 only

Structuring choice: the decree imposes PEPPOL BIS Billing 3.0 as the sole permitted format (with CIUS Belgium, see the dedicated page), and the PEPPOL network as the sole transport channel.

This decision contrasts with the French plurality (Factur-X / UBL / CII) or the German one (XRechnung UBL or CII, hybrid ZUGFeRD). Justifications given in the report to the King:

  • B2G adoption already secured: Mercurius and Hermes have been using PEPPOL-BIS 3.0 since 2020. Tools, validators and training exist.
  • Immediate European interoperability: 35 countries are already on PEPPOL (EU + Norway + UK B2G).
  • No central platform to build: unlike the French PPF or the Italian SdI. Estimated savings of EUR 120M by the FPS Finance in the impact assessment.
  • 4-corner decentralised model: compliant with the ViDA spirit (Action 1) and compatible with the future European e-reporting.

Sanctions and incentives

The text provides for a graduated mechanism entering into force on 1 January 2026, with a 12-month grace period during which only manifest breaches will be sanctioned.

  • Classical VAT sanctions: art. 70 and 70bis VAT Code — fines from EUR 25 to EUR 5,000 per infringement (new art. 14quater extends these sanctions to the absence of a structured invoice).
  • Temporary tax incentive: the Programme Act of 22 December 2023 reintroduced an enhanced investment deduction (EID 13.5% for SMEs, 8% for large enterprises) on PEPPOL-compliant invoicing software, valid for tax years 2024 to 2027.
  • Grace period. From 1 January 2026 to 31 December 2026, monetary sanctions are suspended for first infringements. Non-binding warning letters are sent by the FPS Finance.

Application timeline

text timeline-RD-20-march-2025.txt 
┌────────────────────────────────────────────────────────────────────────┐
│              Implementation timeline (summary)                         │
├────────────────────────────────────────────────────────────────────────┤
│ 2017      Mercurius adopted (federal B2G, contracts > EUR 30,000)      │
│ 2020      Mercurius switches to PEPPOL-BIS 3.0                         │
│ 17 Mar 2025  Council of Ministers approves the draft Royal Decree      │
│ 20 Mar 2025  Royal Decree signed by King Philippe                      │
│ 31 Mar 2025  Publication in the Moniteur belge / Belgisch Staatsblad   │
│ 1 Jan 2026   Entry into force - all domestic B2B operations            │
│ 1 Jul 2030   (likely) ViDA convergence - B2B/B2C e-reporting           │
└────────────────────────────────────────────────────────────────────────┘

Unlike France, the Belgian text enters into force in one go for all companies, with no differentiated schedule by size. The logic is that no new central platform needs to be built — PEPPOL has been operational for B2G since 2017.