North America

Belgium: Limited Grace Period Announced for E-Invoicing Mandate

Tânia Rei
December 3, 2025

The Belgian Tax Administration (FOD Financiën) has announced a three-month grace period for the country’s mandatory B2B e-invoicing requirement, which takes effect 1 January 2026.

Over half a million Belgian companies have already adopted e-invoicing solutions. However, authorities recognize that some businesses may face technical hurdles beyond their control during the initial implementation phase.

Grace Period Details

The grace period is subject to conditions – the Belgian tax authorities will not impose sanctions for e-invoicing violations during the first three months of 2026 if the following conditions are met:

  • Businesses can prove that they have taken timely and reasonable steps to comply with the new obligation;

  • The offence is specific to the new obligation, such as:

    • Lack of technical capabilities to send and/or receive structured electronic invoices;

    • Inability to issue compliant structured electronic invoices due to system limitations, whether internal systems or third-party solutions.

Businesses experiencing these technical issues must continue to fulfil their invoicing obligations through alternative formats or delivery methods during the grace period.

No General Postponement

Belgian authorities emphasized that this tolerance period does not constitute a general postponement of the mandate.

The 1 January 2026 deadline is maintained to preserve the mandate’s intended benefits, which would be delayed by a postponement, and to ensure fairness to the many businesses that have invested resources to meet the original deadline. Each case will be evaluated individually based on the specific circumstances and potential sanctions will depend on the concrete facts of each situation.

For future updates on Belgium and similar developments in other countries, follow our Regulatory Analysis page.

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Author

Tânia Rei

Tânia Rei is a Regulatory Counsel at Sovos, specializing in VAT compliance and global e-invoicing trends. Tânia holds a Bachelor’s degree in Law and a Master’s in Tax Law from Universidade Católica Portuguesa, and has previously worked as a VAT consultant.
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