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Since 1 January 2026, all Belgian VAT-registered businesses have had to use structured electronic invoices for their B2B transactions. If you supply Belgian business customers from the Netherlands, you do not automatically fall under the rule yourself, but your customers do have to be able to receive and process those invoices. In practice that changes what they expect from you.
This article sets out what is mandatory, who it applies to, what it means for cross-border sales and what your B2B ordering environment can and cannot do about it. This is not tax or legal advice; for your own VAT position that is a question for your accountant or tax adviser.
A PDF is not an electronic invoice
This distinction is the heart of the obligation and is often confused.
A PDF invoice is essentially a picture of an invoice. You send it by email or make it available in a customer environment. On the receiving end, someone has to copy the data over or run it through a scanning solution.
A structured electronic invoice is a machine-readable file exchanged directly between the software of supplier and customer. The recipient's accounting system reads the invoice lines straight in, without retyping.
VLAIO describes that under the new obligation invoices are exchanged directly between the software of both businesses, and that sending a PDF invoice by email or through a platform is no longer sufficient (Dutch-language source). Making an invoice available in your customer portal is therefore convenient for the customer, but it is not e-invoicing in the sense of the law.
Peppol as the exchange network
Peppol is the designated channel for that exchange. It works with its own addressing per business, so an invoice does not land in a mailbox but goes straight into the recipient's accounting system. For that you need an access point, usually through your ERP vendor, your accounting package, your invoicing software or a specialised service provider.
Peppol is not a Belgian invention. The Netherlands, Belgium and Luxembourg work together within the Benelux to strengthen cross-border digital business through the Peppol network, and in the Netherlands e-invoicing towards government bodies has been running over that network for some time.
What exactly is mandatory, and for whom
In Belgium. Since 1 January 2026 the obligation applies to B2B transactions between Belgian VAT-registered businesses, regardless of company size. Invoicing to private individuals falls outside it.
When supplying Belgian customers from the Netherlands. The Belgian obligation is aimed at VAT-registered businesses established in Belgium. If you have no establishment in Belgium, you do not automatically fall under it. Your Belgian customers are by now set up to receive and process structured invoices, and they increasingly ask the same of their suppliers. If you hold a Belgian VAT number yourself, the situation is different and tax advice is necessary.
In the Netherlands. There is no obligation yet for domestic B2B transactions. Towards government bodies, e-invoicing is already arranged.
In Europe. The ViDA package makes electronic invoicing and digital reporting mandatory from 2030 for cross-border VAT transactions within the EU (Dutch-language source). For a wholesaler with Belgian or German customers that is no longer a distant subject, but a reason to make the route you set up now usable for the rest of your export markets straight away.
What this means for your B2B ordering environment
You do not become compliant by changing something in your webshop or customer portal. E-invoicing happens in your invoicing process and your ERP. But there are three points where your online environment does make a difference.
Invoice access and e-invoicing are two different things. Make sure no confusion arises internally between "the customer can download his invoices" and "we invoice electronically". The first is self-service, the second is a legal route. A wholesaler who thinks it is all sorted because the PDFs are in the portal is in for a surprise.
One source for invoice data. The amounts, payment statuses, open items and credit notes a customer sees in his account environment have to come from the same administration as the invoices you send through Peppol. If a second administration appears, you get discrepancies your customer calls about at exactly the moment you were trying to reduce those calls.
Treat it as one project. If you are starting work on self-service for invoices and open items and you have Belgian customers, that touches the same data flows as your e-invoicing project. Two separate projects on the same ERP data lead to duplicated work and to decisions that get in each other's way. Which data your ERP can expose, and in what way, is the decisive question in both cases; the overview of ERP integrations gives a picture of the systems for which that route has already been worked out.
Practical first steps
- Map your Belgian customers. What share of your revenue runs through VAT-registered businesses established in Belgium? That sets the urgency.
- Ask your ERP or accounting vendor about the Peppol route. Is an access point available, what does it cost, and what has to happen to your invoice data to meet the format?
- Check your invoice data for completeness. Structured invoices are stricter than a PDF. Missing or inconsistent fields that nobody noticed in a PDF now get rejected.
- Record where your customer sees which invoice information. And make sure that view comes from the same source as the invoice you sent.
- Ask your tax adviser about your own position. Particularly if you hold a Belgian VAT number or are considering one.
The rules around e-invoicing are in motion, in Belgium, in the Netherlands and at EU level. Check the current state of play with the tax authorities, with VLAIO or with your adviser before drawing conclusions for your own organisation.
