E-invoicing mandatory since 2026: what Peppol means for a service company
A customer with an office building calls about the invoice for the maintenance of their heat pump: their accountant no longer accepts PDFs. The same day, a private customer’s invoice simply goes out by email. Since 1 January 2026, those two invoices take different routes.
Published by Abdelhay Rahou (opens in a new window)5 November 20269 min read
What has changed since 1 January 2026
Since 1 January 2026, all Belgian VAT-registered businesses must send each other structured electronic invoices. Such an invoice goes directly from one business’s software to the other’s, via the Peppol network. Between businesses, a PDF by email or via a platform is no longer enough. You must also be able to receive your suppliers’ structured invoices. That is what the official site efactuur.belgium.be (in Dutch) says.
For a service company with technicians, this comes down to four flows:
- Business customers with a VAT number, such as a bakery, a garage or the owner of an office building, receive their invoice as an e-invoice via Peppol.
- Private customers are not covered. Their invoice may still go out as a PDF by email.
- Your suppliers, such as the parts wholesaler, send their invoices via Peppol. You must be able to receive them, even if you only work for private customers.
- Credit notes can use the same network: the government describes Peppol as a network for structured data such as invoices and credit notes. How to issue one is explained in issuing a credit note.
How a completed intervention becomes an invoice without retyping is explained in from work order to invoice.
Who is covered by the obligation?
The obligation depends on your VAT status and your customer’s. According to the official page on who is covered by e-invoicing (in Dutch):
| Situation | Issuing e-invoices | Receiving e-invoices |
|---|---|---|
| Belgian business with an active VAT number, including a sole trader | Mandatory | Mandatory |
| Small business under the VAT exemption scheme for small businesses | Mandatory | Mandatory |
| Business that only carries out exempt transactions (Article 44 of the VAT Code) | Not mandatory | Not mandatory |
| Flat-rate VAT taxpayer (Article 56, phased out by 1 January 2028 at the latest) | Not mandatory | Mandatory |
| Foreign VAT taxpayer without a permanent establishment in Belgium | Not mandatory | Not mandatory |
| Outgoing invoice to a private customer | Not mandatory | Not applicable |
If one of the two parties is not VAT-registered, the obligation does not apply between them. So a non-profit association (vzw / ASBL) without a VAT number does not receive an e-invoice from you; one with an active VAT number does. If you are unsure about the status of your business or of a customer, check it with your accountant.
What is a structured e-invoice?
An ordinary electronic invoice, such as a PDF, has a free form, as long as the mandatory details are on it. A structured invoice is drawn up, sent and received in a structured electronic form, so that your customer’s software can process it automatically. Between Belgian businesses, a PDF is no longer allowed since 2026; for other invoices, such as those to private customers, it remains valid (what is an electronic invoice?, in Dutch).
How the network works:
- Peppol is a secure network for structured data. The invoices use the Peppol BIS format, which follows the European standard EN 16931 (how does e-invoicing work?, in Dutch).
- Access is through certified service providers, also called access points. You need software that can work via Peppol (what do I need?, in Dutch).
- Registration on the Peppol network counts as agreement to receive structured e-invoices.
- If a customer cannot receive, for technical reasons, you are not obliged to send them an e-invoice. You do still issue an invoice on paper or in electronic form, such as a PDF. The customer must take the necessary steps without delay to be able to receive (notice of 19 December 2025, in Dutch).
Tolerance and fines
A general tolerance period applied during the first three months of 2026. According to a government notice of 7 April 2026 (in Dutch), it has ended. In exceptional circumstances, the administration can still decide not to impose a fine, but only after an individual analysis of the case.
The Royal Decree of 8 July 2025 (in Dutch) sets the fines for anyone who does not have the technical means to issue and receive structured e-invoices: €1,500 for a first offence, €3,000 for a second and €5,000 for each subsequent one. An offence only counts as a second or subsequent one if the administration establishes it at least three months after the previous one.
Checklist: what do you prepare?
- Your own details. Your VAT number and company number are correct in your invoicing software.
- Your Peppol registration. It runs through your invoicing software and its service provider. Ask who does it and when it is active.
- Your customer file. Every business customer has a VAT number, checked in the Crossroads Bank for Enterprises (KBO/BCE). Private customers are clearly marked as private.
- Customers not yet on Peppol. Note who they are, send them a PDF for now and ask when they will be connected.
- Receiving. Agree in which software your suppliers’ invoices arrive and how they reach accounting.
- Credit notes. Send a credit note through the same channel as the invoice it corrects.
- Your accountant. If they prepare or process your invoices, agree together who sends and receives what, and check the first e-invoices together.
Looking for a free solution? The government does not recommend any product and writes that e-invoicing does not have to be expensive. Small SMEs and self-employed people with a subscription formula can apply an increased cost deduction of 120% to their invoicing package for the taxable periods 2024 to 2027 inclusive (tax incentives, in Dutch). Whether that applies to you, you decide with your accountant.
An example: a heating installer with three kinds of customers
A heating installer with five technicians works for private customers, for small businesses such as a bakery and a garage, and for the owner of two office buildings. The parts come from one wholesaler.
In December, the office manager goes through the customer file. Three business customers have no VAT number in their record: she adds it and checks it in the KBO/BCE. The private customers stay as they were. With the accountant, she agrees that the wholesaler’s invoices arrive via Peppol in the accounting software, and who checks them there.
In January, the bakery’s invoice goes out via Peppol, with a PDF as a copy to the owner. The garage is not on Peppol yet. The office sends the invoice by email with the PDF, notes this in the customer record and asks the garage when it will be connected. A maintenance visit that was invoiced twice is corrected with a credit note, through the same channel as the invoice.
Short video · 0:30
Nieuwe software, en weken instellen?
U begint bij Aan de slag: bedrijf en facturatie worden nagekeken, Peppol regelt u samen met Digitalnatie, en u nodigt uw collega's uit, elk met zijn rol.
Video in Dutch, with Dutch captions
All short videos (in Dutch)How it works in Digitalnatie Service Suite
- Peppol registration at the start: the onboarding checklist has a Peppol step, with no screen in the application. Registration takes place at the start together with Digitalnatie, with your KBO/BCE number, your agreement and a check.
- Your company details: in the company profile, the administrator enters, among other things, the VAT number and the company number (KBO/BCE). The VAT number is checked when it is saved.
- Your customers: when you create a customer, you enter their VAT number in the format BE0123.456.789. In the customer’s details, the company data lookup takes over the official information (VIES / KBO/BCE), from a VAT number that has already been saved.
- Sending via Peppol: if your organisation is connected to Peppol, sending a posted invoice offers the Peppol channel (e-invoice) when the customer is on Peppol, with email and the PDF as an optional copy. If the customer is not on Peppol, the Peppol option is greyed out, with the reason. A message then confirms that the invoice was sent via Peppol.
- Private customers and customers without Peppol: the invoice goes out by email with the PDF, from your organisation’s connected email account. If you deliver it another way, you mark it as sent and record the channel: your own email, post, handed over or other.
- Credit note: you make it on a posted invoice. It always covers the full amount of the invoice.
- Your accounting software: an API key can, among other things, read the invoices, and a webhook can send a notification when an invoice or credit note is posted. The technical permission for this is not in any role template: ask Digitalnatie for it.
Good to know:
- Peppol registration does not take place in the application: you ask Digitalnatie for it.
- You send invoices one at a time: one invoice per confirmation, with no bulk sending.
- As long as your organisation’s email account is not connected, the invoice says that you must download the document and deliver it yourself.
- By default, the administrator and accounting edit, post, send and credit invoices.
What else the module covers is explained on the invoicing and purchasing page. Getting started with the checklist is described in rolling out new software, and how long to keep invoices and other documents in the document retention period.
Frequently asked questions
Is e-invoicing mandatory for a sole trader?
Yes, if the sole trader has an active Belgian VAT number, even under the VAT exemption scheme for small businesses. It does not apply to invoices to private customers, but you must be able to receive your suppliers’ e-invoices.
Do I have to invoice private customers via Peppol?
No. According to the government’s official information, the obligation does not apply to outgoing invoices to private customers, and a PDF remains valid for them. If you only work for private customers, you must still be able to receive your suppliers’ structured invoices.
Has the Peppol obligation been postponed?
The obligation has applied since 1 January 2026. A general tolerance period applied during the first three months of 2026, which, according to the government, has ended. If a customer cannot yet receive for technical reasons, you issue an invoice on paper or as a PDF, and the customer must take the necessary steps without delay.
What fine do you risk without e-invoicing?
A royal decree of 8 July 2025 provides for €1,500 for a first offence, €3,000 for a second and €5,000 for each subsequent one, for anyone who does not have the technical means to issue and receive structured e-invoices. In exceptional circumstances, the administration can waive a fine after an individual analysis. Check your situation with your accountant.
How do I send an invoice via Peppol in Service Suite?
On a posted invoice, you start sending it and choose Peppol (e-invoice) as the channel. That option appears if your organisation is connected to Peppol and the customer is on Peppol; otherwise it is greyed out, with the reason. Your company’s Peppol registration takes place at the start, together with Digitalnatie.