Belgium: the tolerance period is not a postponement!

Only businesses that have already taken steps will be “spared”

Press release from the FPS Finance (Belgian federal tax administration).

The introduction of mandatory e-invoicing between Belgian VAT-registered businesses from January 1, 2026 is an important step in the digitalization of our economy. In the meantime, more than half a million businesses, large and small, have already made the switch. Many businesses are in their final preparations. Since September, adoption has been accelerating week after week, with a peak expected just before the deadline. The transition to e-invoicing will also be relatively simple for a large share of businesses.

We understand, however, that when implementing e-invoicing, as with any major operational innovation, some practical problems may arise, or that businesses acting in good faith may not yet be able, for reasons beyond their control, to properly meet all their obligations.

Tolerance

For this reason, the FPS Finance will show tolerance during the first three months of 2026 and will not apply penalties for infringements related to the new e-invoicing obligation. This tolerance is granted provided the business can show that it took timely and reasonable steps to comply with the new obligation.

Which infringements are covered?

They must be infringements specific to the new obligation:

• The business does not (yet) have the technical means to send and/or receive a structured e-invoice (in full or for certain transactions, for example issuance by the counterparty [self-billing]).
• The business does not issue a structured e-invoice when required, because its own system, or that of a third party it uses, cannot yet issue a valid e-invoice (in full or for certain transactions, for example issuance by the counterparty [self-billing]).

In these cases, the business must of course meet its invoicing obligations in another way (alternative format or delivery method).

Why the “timely and reasonable” condition?

Businesses that have already made sufficient efforts to apply e-invoicing correctly and on time will be able to get in order without penalty.

Businesses that have not will be encouraged to get in order as quickly as possible.

Any penalty will depend on the specific circumstances of the case. Each case will be assessed individually.

A general postponement is absolutely out of the question. It would be unfair to all the businesses that tried to be ready on time, to everyone supporting them and to all the IT companies that invested to meet the January 1, 2026 deadline.

It would also mean that the benefits of e-invoicing would be pushed back. There is also the additional risk that part of the target group, without any obligation of means, would not meet the new deadline either, simply shifting the problem in time.

Invoicing requires reciprocity: the more counterparties are ready, the smoother the transition.

Conclusion and advice

To benefit from this tolerance until the end of March 2026, you therefore had to have already taken steps. For example by opening your ABCinvoice.eu account, which includes your Peppol access point.