E-invoicing fines in Belgium: what are the risks?

Since 1 January 2026, Belgian VAT-registered businesses must use structured electronic invoices with each other. Businesses that aren’t ready can be fined. Here is what the official texts say.

What is the fine for?

A Royal Decree of 8 July 2025 added a new fine: for not having the technical means to issue and receive a structured electronic invoice. The amounts:

• first infringement: €1,500;
• second infringement: €3,000;
• each further infringement: €5,000.

An infringement only counts as a second or further one if the administration establishes it at least 3 months after the previous fined infringement. So the fine is about not having a working system, not about each invoice separately.

The VAT Code (article 70, § 4) allows fines of €50 to €5,000 per infringement for this kind of breach. The e-invoicing fine sits at the top of that range.

The existing invoice fines still apply

According to the official FAQ, the existing fines for not issuing invoices and for non-compliant invoices also apply to structured e-invoices. That covers, among other things:

• an invoice that is not issued, issued late, incomplete or incorrect;
• other shortcomings, such as not following the technical rules for e-invoices.

The 2018 penalty policy still applies.

Is there still any tolerance?

The general tolerance period ended on 31 March 2026. A separate tolerance for self-billing ran until 30 June 2026. Read more in Is there a delay for Peppol?.

What still applies:

• In exceptional circumstances the FPS Finance can decide not to impose a fine. This doesn’t happen automatically, only after an individual analysis of the file.
• On 22 January 2026 the Minister of Finance told the Chamber that no general moratorium is planned, that whether a fine is imposed always depends on the specific circumstances, and that infringements committed in good faith can be remitted. He also asked his administration to be as flexible as possible during the initial phase.

How to avoid a fine

1. Make sure you can send and receive e-invoices. Choose software connected to Peppol and get registered. See Registering on Peppol. There are also free options, but not every free plan lets you receive.
2. Do you only work for consumers? You still have to be able to receive e-invoices from your suppliers. See Only private customers.
3. Check that you can be found with the Peppol check above.