Since 1 January 2026, an agency must issue a structured electronic invoice whenever its client is a taxable person for Belgian VAT, and it must be able to receive such invoices. Six months later, the tolerance periods are over: what now matters is knowing, invoice by invoice, who the client is for VAT purposes.

Who must issue a structured invoice since 1 January 2026?

The obligation is set out in Article 53, § 2bis of the VAT Code, inserted by the Law of 6 February 2024 and in force since 1 January 2026. A taxable person established in Belgium must issue a structured electronic invoice, in Peppol BIS format, when its client is a taxable person required to provide its VAT number for the transaction. The Law of 10 February 2026 amended this text on two points. Non-established taxable persons are taken out of scope. And a fall-back rule applies: if the recipient is technically unable to receive a structured invoice, the issuer may send an ordinary invoice. According to the federal portal efacture.belgium.be, the obligation also applies to small businesses under the VAT exemption scheme. The criterion is therefore not the client’s legal form, but its VAT status and the transaction.

Who is exempt from the obligation to issue?

The portal lists four exclusions for sending: bankrupt taxable persons, businesses that only carry out transactions exempted by Article 44 of the VAT Code, non-established persons without a permanent establishment, and flat-rate taxable persons until 1 January 2028 at the latest. It adds a simple rule: if one of the two parties is not a taxable person, the obligation does not apply to their transactions. Invoices to private clients therefore remain outside the obligation. But the portal insists: even a business that only invoices private individuals must be able to receive structured invoices from its suppliers.

Where do the tolerance periods stand?

They are over. On 18 December 2025, the FPS Finance announced a three-month tolerance, reserved for businesses able to show that they had taken timely steps. It stated that there was absolutely no question of a general postponement. The same release noted that more than half a million businesses had already joined Peppol. On 7 April 2026, the FPS confirmed the end of this general tolerance. A targeted tolerance remained in place until 30 June 2026 inclusive for self-billing. Since then, the administration may still waive a fine in exceptional circumstances, after reviewing the file, but the FPS warns that this is not automatic. The same page recalls that small businesses under the exemption scheme are in principle also subject to the obligation. The FPS has published no new release on tolerance periods since that date.

What fines does the agency face?

The Royal Decree of 8 July 2025 added a scale to Royal Decree no. 44 on VAT fines. It targets not having the technical means to issue and receive a structured electronic invoice: EUR 1,500 for the first infringement, EUR 3,000 for the second, EUR 5,000 for subsequent ones. An infringement only counts as second or subsequent if it is established at least three months after the previous one. This scale penalises the lack of equipment, not each irregular invoice: other invoicing failures fall under the existing scales. No public figure shows, to date, how many fines have been imposed.

Which flows must an agency distinguish?

Flow Client for VAT purposes Required format
Management fees Taxable company (taxed activity, or VAT option) Structured Peppol invoice
Management fees Company that only carries out exempt transactions (Article 44) Outside the obligation, to be checked case by case
Management fees Private owner Paper, or PDF with the client’s consent
Contractor invoice The taxable agency Structured invoice, which the agency must be able to receive
Contractor invoice The private owner, the agency acting as agent Outside the obligation
Invoice addressed to a co-ownership Association of co-owners not subject to VAT Outside the obligation, status to be checked in the CBE

Who is the client on a contractor’s invoice?

This is the question that decides the format, and it is not settled by looking at who pays. The obligation depends on the contracting party, meaning the client for VAT purposes. If the contractor invoices the private owner and the agency acts only as agent, no structured invoice is required. If the taxable agency orders in its own name and becomes the client, the invoice is structured, and the agency must be able to receive it via Peppol. The debtor named on each purchase order therefore becomes a compliance decision. For a co-ownership, the general rule applies: an association of co-owners is in principle not a taxable person. No official page deals with it by name, and the re-invoicing of works by the agency remains a VAT question to validate with your accountant. The case of the owner who lets many properties is covered in our article on the professional landlord.

What does e-reporting have in store?

On 18 July 2026, on a proposal from Finance Minister Jan Jambon, the Council of Ministers approved a preliminary draft law on the electronic reporting of invoicing data. The supplier and its client will have to send this data to the administration in near real time. For the taxable persons concerned, the annual listing of taxable customers would disappear. The preliminary draft has been sent for opinion to the Data Protection Authority and the Council of State: it is not yet a law. The release gives no date of application. The official FAQ refers to the government agreement, which aims for 2028. For an agency, matching invoice, repair job and payment could then become data that is transmitted, and not just an accounting record.

What checklist for the summer?

  1. Check the VAT status of each owner client: private individual, taxable company, company that only carries out exempt transactions.
  2. Obtain written consent from private owners who receive their fee invoices as PDF.
  3. Test the agency’s Peppol reception before the contractor invoices of July to September.
  4. Set the debtor on each purchase order: agency, owner or co-ownership.
  5. Have re-invoicing of works validated by the accountant.

Fees retained from rents go through the client account, whose rules are detailed in our article on IPI sanctions. How they are presented to the owner is covered in our article on the owner report.

Managing several properties? With Seido’s contractor portal, your own contractors receive the job on their phone and upload their quote and photos to the job file, timestamped. When the invoice arrives, the file that supports it is already in place. See the contractor portal.

Frequently asked questions

Must an agency send a Peppol invoice to a private owner?

No. The obligation only covers transactions between taxable persons: if one of the two parties is not a taxable person, it does not apply. For a private client, the official portal accepts a paper invoice, or a PDF invoice subject to the client’s consent. The agency must, however, be able to receive structured invoices from its own suppliers.

What fine for an agency that cannot receive Peppol invoices?

The Royal Decree of 8 July 2025 provides for EUR 1,500 for a first infringement, EUR 3,000 for the second and EUR 5,000 for subsequent ones. It targets not having the technical means to issue and receive structured invoices. Each step requires a new finding, at least three months after the previous one.

Has the administration’s tolerance been extended?

No. The tolerance of the first quarter of 2026 ended on 31 March, and the one for self-billing on 30 June 2026. According to the FPS Finance, the administration may still waive a fine in exceptional circumstances, after reviewing the file, but this decision is not automatic. No new release has been published since 7 April 2026.

Must an invoice addressed to a co-ownership go through Peppol?

In principle no, because an association of co-owners is as a rule not subject to VAT, and the obligation only applies between taxable persons. Its status can be checked in the Crossroads Bank for Enterprises, under the qualifications heading. No official source deals with this case by name: have re-invoicing of works validated by your accountant.

Must a property holding company receive structured invoices?

It depends on its VAT status. A company that only carries out transactions exempted by Article 44 of the VAT Code, such as residential letting, is among the exclusions listed by the official portal. If it has opted for VAT on certain lettings or carries on another taxed activity, it is an ordinary taxable person, and the agency’s fees must reach it as a structured invoice.

Sources and references

Last updated: July 2026. This article is provided for information purposes only and does not constitute legal advice. For any specific situation, consult a real estate law professional.