In addition to the three-month grace period allowing good-faith companies to avoid penalties, the Belgian government has published a draft law [↗︎] containing three key provisions to refine the upcoming obligations:
- ViDA alignment and technical anticipation: the regulation aligns with upcoming VAT in the Digital Age (ViDA) Directive by anticipating technical standards and adapting the VAT Code to ensure future-proof compatibility with European digital reporting requirements.
- Scope adjustment regarding non-established: in line with updated EU authorizations and following administrative clarifications, the mandate officially excludes VAT-registered taxpayers not established in Belgium. However, it maintains the obligation for foreign entities that possess a fixed VAT establishment within the country.
- Authorisation to issue paper or non-structured electronic invoices if Buyer not ready: as of mid-December, nearly half a million Belgian companies were still not registered on the Peppol network, and therefore not ready for the electronic invoicing obligation. In line with the three-month grace period, the draft law acknowledges the existing technical challenges and will formally allow vendors to deviate from the mandate if a buyer is not yet technically ready. In such cases, vendors may temporarily continue “to issue invoices in paper or unstructured electronic formats (e.g., Word or PDF)”.
Companies Must Complete Peppol Registration
It is now urgent for companies that are not yet registered on the Peppol network to do so as soon as possible, and at the latest before the end of the grace period. According to the official requirements, registration must be completed using the CBE number (scheme identifier “0208:”).
Additional challenges tied to Peppol can also be encountered, particularly when recipients:
- Use non-compliant CBE numbers (for example 0208:be0000000000)
- Use multiple Peppol identifiers (0208 and 9925)
- Register themselves but do not support the mandatory Peppol BIS Billing format
These issues should naturally be resolved over time, notably through the actions and guidance of Peppol service providers.
Impact of Hermes Decommissioning
Another issue regarding Peppol registration was linked to the Hermes solution.
Implemented by the Belgian authorities, Hermes provided a temporary, free solution that allowed Belgian companies to exchange structured electronic invoices. It automatically converted these invoices into human-readable PDFs, ensuring that recipients not yet equipped to handle structured e-invoices could still process them.
In addition, Hermes automatically registered all Belgian companies’ CBE Enterprise Numbers as receivers on the Peppol network. As a result, Hermes functioned as Belgium’s default Peppol “receiver”, allowing any Peppol sender to use the network without having to verify the recipient’s technical readiness.
However, this setup created a significant issue for companies registered via Hermes. Because it was set as their receiving solution, registering a new Peppol service provider to receive invoices was difficult, as replacing the existing receiver (Hermes) in Peppol required to follow a complex migration process.
The decommissioning of the Hermes solution on December 16, 2025, removed this major obstacle, allowing companies to register again on the Peppol network with their own dedicated and compliant e-invoicing solution.
