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Does the e-invoicing obligation apply under the small business VAT exemption scheme?

Yes. Businesses using the small business VAT exemption scheme (annual turnover up to 25,000 euros) are in principle also covered by the obligation. The government stressed this explicitly after confusion in the media.

Last checked 25 October 20261 min readSources

The small business VAT exemption scheme means you don’t charge VAT. Because of that, many small sole traders thought the e-invoicing obligation didn’t apply to them. That isn’t right.

What does the government say?

According to the official FAQ, the obligation applies even if you use the small business VAT exemption scheme, so if your annual turnover is no more than 25,000 euros. After reports in the media, the government stressed once more that these VAT-registered businesses are in principle also covered by the obligation.

What do you actually need to do?

  • Invoices to Belgian businesses: send them as a structured e-invoice via Peppol.
  • Invoices to private customers: the obligation doesn’t apply to these.
  • Invoices from your suppliers: you need to be able to receive them as e-invoices.

Only businesses that don’t issue any invoice to, or receive any invoice from, Belgian VAT-registered businesses fall outside it. Also read I only work for private customers. Do I need to send e-invoices?.

How do you get started?

Choose software that is connected to Peppol; that’s also how you get registered on Peppol. The government’s list also includes solutions that are partly free or available at a limited price. Read How do I register my business on Peppol?.

Read the full guide: Is e-invoicing mandatory for me?

Frequently asked questions

I don't charge VAT. Why does it apply to me?
Because you are VAT-registered, even if you don't charge VAT. The official FAQ says explicitly that the obligation also applies under the small business VAT exemption scheme.
I only work for private customers. Do I still need to do anything?
You don't need to send e-invoices to private customers, but you do need to be able to receive e-invoices from your Belgian suppliers.
Are there tax benefits for small businesses?
Small SMEs and self-employed people with a subscription to invoicing software may temporarily deduct 120 % of those costs. Ask your accountant whether this applies to you.

Related guides

Is e-invoicing mandatory for me?

The complete guide to Belgium's e-invoicing obligation since 1 January 2026: who it applies to, the exceptions, the tolerance period, and what to do if a customer or supplier isn't ready.

I only work for private customers. Do I need to send e-invoices?

You don't need to send e-invoices to private customers. But you do need to be able to receive them if you have an active VAT number. Here's how it works.

How do I register my business on Peppol?

You can't register on Peppol yourself. This is how registration does work, through your software or a Peppol service provider, and how to check the result.

Sources

This guide is general information, checked against the official sources above. It is not legal or tax advice; for your own situation, ask your accountant or software provider.