Belgium’s e-invoicing plans could expand to non-resident businesses by 2028

When Belgium confirmed its B2B e-invoicingElectronic invoicing - widely referred to as e-invoicing - is the exchange of a digital document between a supplier and a buyer. E-invoices are issued, transmitted and received in a structured data format that enabled automatic and electronic processing. They contain data in a machine-readable format so that an AP system can read an invoice without manual data entry, leading to faster and more efficient invoicing. mandate for 2026, one group was intentionally left outside the scope: non-established businesses that only hold a Belgian VAT registration.

Under the current framework, the obligation only applies where both the supplier and customer are established in Belgium. But that position may not last for long.

Attention is already shifting towards Belgium’s next phase of reform, with draft legislation for 2028 expected before the end of 2026. The big discussion point? Whether mandatory e-invoicing and e-reporting requirements will also be extended to non-resident taxpayers.

If that happens, Belgium could become one of the first EU member states to push domestic digital reporting obligations onto non-established entities ahead of the EU’s wider ViDAViDA or 'VAT in the Digital Age', is an EU initiative proposed by the European Commission that seeks to modernise and harmonise VAT processes for member states, by embracing new technologies. It is aimed at updating processes for the management of VAT, and reduce the VAT gap and fraud. The proposal also aims to address challenges in the area of VAT raised by the development of the platform economy. reforms coming in 2030.

And that could have implications far beyond Belgium.

What’s being discussed for 2028?

The current expectation in the market is that Belgium’s 2028 reforms will introduce mandatory near real-time e-reporting alongside an expansion of the existing e-invoicing rules, all built around the Peppol framework.

The proposals being discussed include:

• Mandatory e-invoicing for transactions involving non-resident VAT registered businesses
• E-reporting obligations for both supplier and customer
• Removal of the annual customer listing (“Jaarlijkse Klantenlisting”), which currently reports sales above €250 to Belgian VAT registered customers

From a technical and policy perspective, the direction of travel makes sense. Once tax authorities move towards near real-time transaction reporting, it becomes increasingly difficult to justify gaps in coverage. Structured reporting relies on structured invoice data and excluding non-resident businesses creates blind spots in that model.

But the challenges are hard to ignore

While the proposal may appear logical from a data collection standpoint, it raises several important questions.

One of the biggest is whether Belgium has the legal competence to impose domestic e-invoicing obligations on non-established businesses in every scenario. In some cases, approval or at least scrutiny from the European Commission may be required.

If Belgium secures support for this approach, it could set an important precedent for other upcoming domestic mandates across Europe, including countries like Spain, Netherlands and Ireland, all of which are developing their own digital reporting frameworks ahead of ViDA.

There’s also a practical question around value versus burden.

Because transaction data would already be reported by the Belgian-established counterparty, some businesses will question what additional compliance benefit is gained by forcing non-resident suppliers into the same reporting ecosystem.

For many organisations, this starts to look less like simplification and more like another administrative layer added onto cross-border EU trade – something policymakers are especially sensitive to as economic growth across the Single Market remains under pressure.

Belgium’s reform journey is becoming more complex

What originally looked like a relatively straightforward domestic e-invoicing rollout is now evolving into multiple overlapping phases of reform:

• 2026 – Domestic B2B e-invoicing for Belgian-established entities
• 2028 -Near real-time e-reporting requirements introduced
• 2028 (possible) – Inclusion of non-established businesses within scope
• 2030 – EU-wide intra-community digital reporting under ViDA

For non-resident businesses, this could represent a major shift in operating model.

Today, many businesses trading into Belgium rely heavily on local customers or existing VAT compliance processes to manage invoicing obligations. A 2028 expansion would likely mean implementing full Peppol capability, updating determination logic, aligning reporting workflows and reassessing compliance responsibilities entirely.

Are businesses prepared for the next phase?

One thing is becoming increasingly clear across Europe: e-invoicing projects are no longer static compliance exercises. The scope keeps evolving, timelines move, and what sits outside a mandate today can quickly become tomorrow’s requirement.

At Innovate Tax, we work with businesses navigating complex global e-invoicing and digital reporting reforms. You can find out more about our services here.