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Dynatos is your strategic partner in Finance & Procurement automation. Measurable Results, Noticeable impact.
Last update: 2024, April 29
B2G E-Invoicing
B2G invoice acceptance by public entities is mandatory since 2019.
All Suppliers are required to issue electronic invoices, with very few exceptions.
Public infrastructure is based on the “Mercurius” platform and the Peppol network.
B2B E-Invoicing
Currently allowed using EDI, e-signature or guaranteeing a complete audit trail.
E-invoicing will become mandatory country-wide starting 1.1.2026
Belgium provides “Hermes” platform to actively support initial e-invoicing adoption.
What the Law Says
B2G E-Invoicing
All Belgian public authorities accept electronic invoices since 2019.
All suppliers are now required to issue electronic invoices, following a phased roll-out that took place starting from 2022. For contracting authorities in the Brussels region, the supplier mandate started in November 2020.
But e-invoicing is not mandatory in all cases: old tenders dating from before the deadlines, or new tenders below 3,000 €, as well as some tenders from specific public companies such as VRT, SNCB or bpost remained exempted from obligatory e-invoicing.
When e-invoicing is possible and/or mandatory, public infrastructure is based on the “Mercurius” platform and the Peppol network.
Suppliers are encouraged to use Peppol BIS 3.0 invoices using the CBE as identifiers. Alternatively, manual invoice creation is available, too. The Mercurius platform allows to keep track of submitted invoices.
B2B E-Invoicing
Currently, domestic invoices between private companies are allowed in mutually agreed formats including paper, (unstructured) PDF, EDI formats (EDIFACT- or XML-based) as long as they can be made humanly readable upon audit.
Any transmission channel is valid as long as a complete business audit trail is available.
Electronic B2B invoicing will become mandatory on 1.1.2026 as the law has been voted by the parliament at the beginning of 2024.
The 2020 coalition agreement includes the objective to reduce VAT gap to the level of Belgium’s neighbors. A working group was established on e-invoicing and e-reporting.
E-Invoicing is considered a pre-requisite to e-Reporting with the added benefit of improving economic efficiency. E-Reporting is the implementation of EU-wide Digital Reporting Requirements (DRR) to improve VAT collection.
Timeline
B2G E-Invoicing Mandate - Mandatory Acceptance
Public authorities are required to accept electronic invoices.
B2G E-Invoicing Mandate
All suppliers are required to issue electronic invoices.
B2B E-Invoicing Mandate
Electronic B2B invoicing is planned to become mandatory.
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Resources
Public entity supervising the e-invoicing mandates in Belgium
E-invoicing homepage & resources on the BOSA website
Belgium B2G central platform
Tool provided by the government to facilitate the move to e-invoicing for companies
Educational website about e-invoicing in Belgium, managed by BOSA
Entire set of official Peppol BIS 3.0 specifications
Technical Details (B2G)
Identification
All public purchasing entities are registered in the “Crossroads Bank for Enterprises” (CBE) the same as private economic operators. This registry assigns a 10-digit “Enterprise Number” used to identify the issuer and recipient of the invoice. Alternatively, the VAT number (comprised of country code “BE” plus the Enterprise Number) is also possible. The registry is publicly available to find the required Enterprise Number if not given in the ordering process.
Invoice Content and Format
Belgium invoice content is required to comply to the European Norm (EN) 16931 created for Directive 2014/55/EU.
As a technical format, Belgium uses the Peppol BIS 3.0 Invoice format as a standard.
Implementation
B2G electronic invoices are centrally handled in the “Mercurius” platform.
Private companies can submit invoices through:
- use of the Peppol network (preferred)
- or manual data entry
Mercurius also allows to track delivery of the invoice to the final recipient in the public administration. Senders can register and identify using their electronic identification card (“eID”).
Within the public administration, Mercurius is available as an “invoice inbox” listing inbound invoices and can be integrated with the internal accounting systems of the contracting agencies.
Technical Details (B2B)
Current
Any transmission channel for domestic invoices between private companies is allowed in mutually agreed formats including
- Paper-based invoices, (unstructured) PDF
- EDIFACT– and XML-based formats as long as they can be made humanly readable upon audit
Invoices must be stored for 7 years.
The Hermes Platform to Facilitate E-Invoicing Adoption
To help in initial e-invoicing adoption, a public default delivery system named “Hermes” is provided free of charge. Hermes automatically registers all Belgian companies’ CBE Enteprise Numbers for free as receivers in the Peppol network. Therefore, Hermes acts as the default “receiver” in the Peppol network, so any Peppol sender can use its infrastructure. Hermes generates a human-readable rendition of the XML-format invoice and uses an e-mail address from a specific invoice field to deliver the XML and PDF as an E-Mail. The receiver can then import the invoice into its accounting system or process it manually, if not possible in another way.
Any receiver can at any time migrate its registration to a commercial service offering a higher degree of integration, supporting automation. Belgium anticipates terminating the Hermes service once adoption of commercial Peppol services have rendered the functionality obsolete.
and the use of the Hermes platform for companies not ready for e-invoicing
Upcoming B2B E-Invoicing Mandate (starting from 1.1.2026)
Belgium specifically advocates with the EU for ambitious rules around e-Reporting, its early enforcement and proposing interoperable e-invoicing technologies.
Invoice content will to follow the plain “Peppol BIS 3.0 Invoice” standard of the Peppol network, again using the “Enterprise Number” or “VAT Number” for party identification.
The law will allow an option for companies to use different content (and network technology) to fulfill specific business needs and/or protect existing investments, as long as both the sender and the receiver agree.
The mandate aims at standarizing on Peppol network to transport invoices de-centrally between economic operators.
Resources
Public entity supervising the e-invoicing mandates in Belgium
E-invoicing homepage & resources on the BOSA website
Belgium B2G central platform
Tool provided by the government to facilitate the move to e-invoicing for companies
Educational website about e-invoicing in Belgium, managed by BOSA
Entire set of official Peppol BIS 3.0 specifications
The Invoicing Hub Word
Belgium B2G is consistently based on international standards, with Mercurius.
- Extending accessibilty offering manual invoice data entry, particularly to SMEs
- Improving trust through transparency about invoice delivery progress
Some remaining gaps on the recipient side have been closed recently, as the last group of suppliers has been included to the mandate.
For a B2B mandate, the focus on employing plain standards by default is continued.
The Hermes system addresses the initial stalemate of “missing receivers” to accelerate adoption of senders. The adoption of commercial recipient services may be slower than desired because of competition against a “free” alternative.
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Dynatos is a trusted advisor and strategic partner for finance and procurement transformation. We strive for continuous perfection by bringing expertise, inspiring ideas, and innovative technologies to make your organization work digitally, more efficiently, and future-proof.
Together with our technology partners (Coupa, Kofax, Microsoft) and our own platform Routty, we deliver innovative solutions for source-to-pay, purchase-to-pay, contracts, vendor management, document processing, e-invoicing, analytics, and reporting. Our solutions compliment the ERP-system, improving functionality and collaboration for both internal and external stakeholders.
Together with our technology partners (Coupa, Kofax, Microsoft) and our own platform Routty, we deliver innovative solutions for source-to-pay, purchase-to-pay, contracts, vendor management, document processing, e-invoicing, analytics, and reporting. Our solutions compliment the ERP-system, improving functionality and collaboration for both internal and external stakeholders.
