Belgium has published an updated draft law covering multiple VAT-related topics, including changes to the B2B e-invoicing mandate, just weeks before the 1 January 2026 implementation date.
The updates address practical implementation concerns and align Belgian legislation with recent EU developments, particularly the ViDA Directive adoption.
What’s Changed
Non-Established Entities Formally Excluded
The draft law now explicitly removes non-established entities with Belgian VAT numbers from the mandate’s scope. This formalizes previous tax administration guidance, providing legal certainty for companies registered for Belgian VAT but lacking permanent establishment in the country.
Issuer Relief for Recipient Technical Limitations
A new provision releases suppliers from structured e-invoice requirements when buyers cannot receive compliant electronic invoices. Issuers must then provide regular invoices through alternative formats.
ViDA Directive Integration
The legislation removes conditional language previously tying implementation of the mandatory e-invoicing to EU Council authorization. With the ViDA Directive’s March 2025 adoption, Belgium now has direct authority to implement its e-invoicing mandate without seeking derogation.
Timeline Remains Firm
Despite these refinements, 1 January 2026 stays as the mandatory compliance date.
This approach, combined with this week’s three-month penalty grace period announcement, balances implementation pressure with practical support for compliant businesses facing technical challenges.
For future updates on Belgium and similar developments in other countries, follow our Regulatory Analysis page.
