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Belgium

Belgium – Grace Period for Mandatory B2B E-Invoicing Requirement 

Belgium’s Revenue Administration shared on December 2, 2025, that it will introduce a three-month grace period for domestic businesses that couldn’t establish an invoicing/reporting system that incorporates all parts of the new e-invoicing regime. 

The implementation date of the domestic B2B e-invoicing mandate remains unchanged; nothing changes on that front. Starting from January 1, 2026, resident taxable persons are obligated to comply with the e-invoicing requirements accordingly. 

The Revenue Administration shared information that, based on their finding, more than half a million domestic businesses are fully aligned with the new requirements. However, there is also supporting evidence that many companies will not be able to develop an internal system or integrate with third-party providers promptly. 

Tolerance period 

A domestic business that can demonstrate(factually) that even with sufficient efforts, it cannot comply with the e-invoicing mandate from January 1, 2026, could adhere to the tolerance period, in which it will not be penalized for non-compliance. 

It goes without saying that the invoicing requirements must be fulfilled through alternative, acceptable methods. These taxable persons will likely continue to comply with the invoicing requirements in the same way they have so far, and will do so until they complete the transition to the e-invoicing regime. 

Non-Penalty 3 Months Period 

Types of offences tolerable in the grace period: 

  • Taxable persons don’t have the technical means necessary to issue and/or receive e-invoices 
  • A taxable person cannot issue e-invoices, even though it is mandatory, because it hasn’t yet developed an adequate invoicing system, or a third-party service provider hasn’t done so

Tax Authority Control

Tax Authorities will review the eligibility of taxable persons who couldn’t comply with the e-invoicing requirement in due time on an individual basis.

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