The time is now: Royal Decree on electronic invoicing published
The time is now: Royal Decree on electronic invoicing published
On July 14, the Royal Decree was published, aligning various other Royal Decrees with the obligations regarding electronic invoicing. This is notably late, considering the obligation for electronic invoicing comes into effect on January 1, 2026. More background on this obligation, and which businesses/actions fall under these obligations can be found on our general page (link).
Below, we summarize the key points.
The Royal Decree further clarifies that there can only be a second and subsequent offense if it is noticed by the authorities at least three months after the previous violation was identified. In other words, if a violation is identified (and fined), a taxpayer has three months to ensure that their systems are compliant.
Existing fines for failing to issue an (e-)invoice and for incomplete or incorrect issuance of (e-)invoices also remain applicable.
Contact our VAT experts for support or advice at btw-tva@bdo.be or directly with one of the following members of the VAT team:
Below, we summarize the key points.
Format requirements for electronic invoices
- The Peppol network serves as the standard transmission channel for e-invoices.
- The standard format is Peppol BIS (UBL). The use of another format, which must comply with European standards EN 16931, is only permitted in case of mutual agreement between both parties.
- Businesses must always be able to send and receive Peppol BIS invoices, even if another format has been agreed upon.
- It is expected that the Peppol network and the standard format Peppol BIS will become even more important, considering the upcoming implementation of E-reporting.
New rounding rules
With the publication of the new Royal Decree, the rounding rules for VAT on invoices are slightly modified. For electronic invoices, rounding at line level (e.g. per product) is no longer allowed. Rounding must occur at the invoice level for electronic invoices.New fines
As of 1 January 2026, businesses that are technically unable to send or receive e-invoices via the Peppol network will be sanctioned according to the following fine scales:- First offense: €1,500.00
- Second offense: €3,000.00
- Third and subsequent offenses: €5,000.00
The Royal Decree further clarifies that there can only be a second and subsequent offense if it is noticed by the authorities at least three months after the previous violation was identified. In other words, if a violation is identified (and fined), a taxpayer has three months to ensure that their systems are compliant.
Existing fines for failing to issue an (e-)invoice and for incomplete or incorrect issuance of (e-)invoices also remain applicable.
Conclusion
Although the Royal Decree was published rather late, it does provide some clarification regarding the upcoming obligations concerning electronic invoicing. If your business has not yet started the transition to electronic invoicing, we recommend taking action as soon as possible, especially since the Royal Decree also provides for fines for businesses that do not comply with these obligations in a timely manner.Contact our VAT experts for support or advice at btw-tva@bdo.be or directly with one of the following members of the VAT team: