Mandatory e-invoicing to be introduced in Belgium

The Belgian government has approved a draft Royal Decree to introduce mandatory e-invoicing for Business to Government (B2G) supplies. Currently, the obligation to issue e-invoices to public bodies only applies at the regional Government level, including Flanders and Brussels-Capital Region.

The new mandate will be introduced in a phased approach with e-invoicing required based on the value of the individual Government contract. The exact dates will be confirmed when the final legislation is passed as the phases below are based on 6, 12 and 18 months after the Decree is published in the Official Gazette).

Phase

Government contract value

Expected Implementation Date

1

EUR 214,000

September 2022

2

EUR 30,000

March 2023

3

Under EUR 30,000 (all)

September 2023

Contracts with a value of less than EUR 3,000 will be exempt from mandatory e-invoicing but each level of Government in Belgium can decide to waive this exemption or introduce a different phased introduction date.

In addition, while it hasn’t been formally confirmed, it has been widely reported and anticipated that Belgium will quickly move from mandatory B2G e-invoicing to mandatory B2B e-invoicing. This is the general approach of tax authorities as they pilot new mandates and systems for B2G before scaling the scope and volume of e-invoicing to wider business to business transactions. Last year, Belgium’s Minister of Finance Vincent Van Peteghem released a policy note in relation to the 2022 Budget Agreement, which reaffirmed the Belgian Government’s intention to introduce mandatory e-invoicing for B2B transactions. While there is still no formal confirmation on when this mandate will be introduced in Belgium, a legislative proposal for e-invoicing is expected later this year. It has been reported that the B2B e-invoicing mandate will again be introduced in a phased approach based on the size of Belgian companies:

Company Size

Expected Implementation Date

Large

July 2023

Medium

October 2023

Small

2024

Belgium’s VAT Gap for 2019 was estimated to be EUR 4.4 billion (representing 12.3% of lost VAT). E-invoicing is being implemented by many countries across Europe to reduce fraud, increase tax collection and compliance, and reduce the VAT Gap. Belgium currently relies on the PEPPOL (Pan-European Public Procurement Online) interoperability model (i.e. PEPPOL eDelivery Network) which allows any organisation to send and receive e-invoices via their chosen PEPPOL-accredited Service Provider. In addition, for B2G, there is the Mercurius “mailroom” platform that enables Belgian public authorities to receive e-invoices. Mercurius is part of the PEPPOL eDelivery Network.

Find out more about Avalara's e-invoicing solutions.

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