Is Peppol mandatory for you in Belgium? Who must use it
Is Peppol mandatory for a self-employed person? Yes: according to the FOD BOSA, since 1 January 2026 you must use structured e-invoices if you have an active VAT number and invoice a Belgian VAT-registered business, and a PDF by email is then no longer enough. Whether the small-business VAT exemption (vrijstellingsregeling / régime de la franchise) or being self-employed alongside a job (zelfstandige in bijberoep / indépendant complémentaire) changes that, you can read below.
Is Peppol mandatory for a self-employed person with a VAT number?
Yes: since 1 January 2026, all Belgian VAT-registered businesses must use structured e-invoices between themselves, and a PDF that you send by email or through a platform is then no longer enough. That is what the FOD BOSA writes. The test is an active VAT number: if you have one, the obligation applies to your business too, apart from a limited number of exceptions.
The legal basis is art. 53, § 2bis of the VAT Code (WBTW), inserted by the law of 6 February 2024. The text is in the Chamber’s bill DOC 56 1205/001; the Chamber (de Kamer / la Chambre) is the federal parliament’s lower house. Where this obligation fits into your invoicing, you can read in Invoices and Peppol.
According to the FOD, Peppol invoices travel over the Peppol network, in the Peppol BIS format. Another format that respects EN 16931 is allowed only if both parties agree on it between themselves. Peppol itself is covered briefly in Peppol in Belgium, and if you want to understand the network, read What is Peppol?.
According to the FOD’s FAQ, the structured e-invoice is the only invoice that is legally mandatory. What changes in 2026 is explained in E-invoicing in Belgium.
Whether a client is VAT-registered, you can see in the KBO / BCE, the Crossroads Bank for Enterprises, Belgium’s business register. For a VAT-registered business, the section Hoedanigheden (Capacities) shows the entry “Onderworpen aan btw - Sinds [datum]” (Subject to VAT - Since [date]), says the FOD. Look the client up in the KBO’s public search. The FOD also has a tool that checks whether your business falls under mandatory B2B e-invoicing.
The obligation requires a VAT number on both sides and applies between Belgian businesses. Which cases fall outside it, you can read in the next sections.
Does Peppol also apply under the small-business VAT exemption and to someone self-employed alongside a job?
Yes, for both: the FOD confirms it for the exemption, and for self-employment alongside a job your VAT number counts, not your status. The FAQ says the obligation also applies if you use the small-business VAT exemption, so if your business’s yearly turnover is no more than €25,000. From here on we call it the exemption.
The FOD repeated that on 7 April 2026 in its news item on the end of the general tolerance period: businesses under the exemption are in principle covered by the obligation. A small self-employed person with a VAT number is therefore bound just like any other VAT-registered business.
On self-employment alongside a job, the FOD’s pages say nothing, and the law names no status. The criteria in art. 53, § 2bis are the establishment in Belgium, the VAT identification number, the nature of the supply and the client. Someone self-employed alongside a job with an active VAT number is therefore in the same position as someone self-employed as a main job. That is our reading of those criteria, not a sentence from the FOD.
The exemption of art. 56bis is not the art. 44 exemption for certain transactions. The art. 44 exemption puts anyone who carries out only such transactions outside the obligation, as the fourth section explains.
And if I invoice only private individuals, clients abroad or clients without a VAT number?
To a private individual, a client abroad or a client without a VAT number you do not have to send a structured e-invoice, but you must be able to receive them yourself from your Belgian suppliers. According to the FOD, the obligation does not apply to transactions between two parties when one of them is not VAT-registered, nor to outgoing invoices to private clients. A structured invoice to a private individual is allowed, if the recipient agrees: a registration on the Peppol network counts as agreement.
The obligation applies between Belgian businesses. A VAT-registered business that is not established in Belgium and has no permanent establishment falls outside it, says the FOD, even if it is VAT-identified in Belgium. With a client abroad, Peppol is voluntary: it is possible if both parties choose it, says the FOD on its page on e-invoicing outside Belgium.
Public contracts are a different rule. According to the FOD, electronic invoicing is mandatory for contracts published after 1 March 2024, as a rule from €3,000 (excl. VAT), and specific regulation applies to them.
If you sell only to private individuals, you must still be able to receive structured e-invoices from your suppliers, says the FOD. The Chamber’s bill puts it this way: the recipient must be able to receive that invoice, himself or through a third party, in the format in which it was issued.
For private clients and clients abroad, BravoLisa creates PDF invoices, and for those clients a PDF invoice remains possible. BravoLisa sends or receives nothing through Peppol. If your client is a Belgian VAT-registered business, you need another Peppol solution.
Which VAT-registered businesses fall completely outside it?
Outside the obligation fall bankrupt VAT-registered businesses, anyone who carries out only art. 44 transactions, non-established VAT-registered businesses without a permanent establishment and flat-rate VAT-registered businesses, says the FOD:
- bankrupt VAT-registered businesses;
- businesses that carry out only transactions that art. 44 of the VAT Code exempts;
- VAT-registered businesses not established in Belgium without a permanent establishment, even if they are VAT-identified in Belgium;
- flat-rate VAT-registered businesses (art. 56 of the VAT Code), a scheme that ends by 1 January 2028 at the latest.
For receiving, the FOD’s list of exceptions is shorter: it has two points, the businesses that carry out only transactions exempted by art. 44 and the VAT-registered businesses not established in Belgium without a permanent establishment. Flat-rate and bankrupt VAT-registered businesses are not on it.
The small business under art. 56bis is on neither list, as the second section said.
What do I risk if I do not comply with Peppol, and is the tolerance over?
According to the FAQ on e-invoicing, not having the technical means to issue and receive structured e-invoices results in a fine of €1,500 for a first offence, €3,000 for a second and €5,000 for each one after that. An offence counts as a second or later one only if the administration establishes it at the earliest three months after it established the previous offence, which led to an administrative fine.
The tolerance is over. According to the news item of 18 December 2025, the general tolerance period applied to the first three months of 2026 and expressly not as a general postponement. According to the news item of 7 April, the tolerance for self-billing ran until and including 30 June 2026. According to that same news item, in exceptional circumstances, after an individual examination, it can still be decided not to impose a fine. The story of that period is in Peppol postponement.
If you are bound, you need a connection. How you register your business on Peppol through an access point (a certified Peppol service provider: Peppol-dienstverlener / point d’accès Peppol) you can read separately, as well as what it costs.
If your client is not ready to receive invoices through Peppol, you may as sender choose another way of transmission, says the FOD. The Chamber’s bill then lets the issuer send a non-structured invoice, for example on paper or as a PDF, but he remains obliged to invoice. The client runs the risk of being sanctioned.
Frequently asked questions
Is Peppol mandatory for the self-employed?
Yes, if you have an active VAT number and invoice a Belgian VAT-registered client. The FOD BOSA says structured e-invoices are then mandatory, and a PDF by email is not enough. The test is your VAT number, not your status. Invoicing private individuals falls outside the obligation.
Since when is Peppol mandatory?
Since 1 January 2026, according to the FOD BOSA. From that day Belgian VAT-registered businesses use structured e-invoices between themselves, and that happens through the Peppol network. The general tolerance period for the first three months of 2026 is over, and the tolerance for self-billing also ended on 30 June 2026.
Do I have to use Peppol if I am exempt from VAT?
Yes, even if you apply the small-business VAT exemption. The FOD says the obligation applies then too, with yearly turnover up to €25,000, and repeated on 7 April 2026 that such businesses are in principle covered. Anyone who only carries out transactions that art. 44 exempts is outside it, as are a few other groups.
Does Peppol also apply to someone self-employed alongside a job?
Yes, if you have an active VAT number. The rule turns on that number, your establishment in Belgium, the nature of your supply and your client: the law names no status. With a VAT number, being self-employed alongside a job is therefore the same position as a main job. The FOD does not say so in so many words.
Do I have to use Peppol if I only work for private clients?
You do not have to send a structured e-invoice: the obligation does not apply to outgoing invoices to private clients. You must be able to receive them, though. If you buy from Belgian VAT-registered suppliers, you must be able to receive their structured e-invoices, says the FOD BOSA, even if you only sell to private individuals.
Checking your own situation once is enough: after that you know which invoices are Peppol invoices and which are not.
💜💙 Your BravoLisa Team
This article is for general information purposes only and does not constitute professional tax, legal, or accounting advice. Every situation is different — consult a qualified professional (tax adviser, accountant, or lawyer) for advice specific to your circumstances. BravoLisa does not accept liability for decisions made based on this information.
Sources (9)
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- De Kamer — Wetsontwerp, DOC 56 1205/001, artikel 53, § 2bis van het Btw-Wetboek
- efactuur.belgium.be — Algemene vragen over de B2B-verplichting
- FOD Economie — Kruispuntbank van Ondernemingen, openbare zoekfunctie
- efactuur.belgium.be — Valt mijn bedrijf onder de verplichte B2B e-facturatie?
- efactuur.belgium.be — Einde van de algemene tolerantieperiode voor e-facturering
- efactuur.belgium.be — Kan ik e-facturering ook toepassen buiten België, internationaal?
- efactuur.belgium.be — Specifieke vragen over e-facturering
- efactuur.belgium.be — Tolerantieperiode eerste drie maanden 2026