Self-employed liberal professionals are not required to send e-invoices to their clients via PEPPOL in 2026. This requirement is only for B2B transactions between companies subject to VAT. Since liberal professions are exempt from VAT, the new rule doesn’t apply.
Are you self-employed in a liberal profession and are a mixed VAT taxpayer? In this case, electronic invoicing is mandatory for the part of your activity that is subject to VAT.
In this article, we explain in detail when you do and don’t need to send electronic invoices.
What is a liberal profession?
As a reminder, liberal professions are independent occupations that require specific training or qualifications. When you’re self-employed in a liberal profession, you often need to adhere to a code of ethics overseen by professional organisations.
The most common liberal professionals are accountants, pharmacists, architects, doctors, physiotherapists, psychologists, nutritionists and real estate agents. The complete list of liberal professions is provided in Article 44 of the VAT Code (page available in French/Dutch/German).
Are liberal professions subject to VAT?
Liberal professions are not subject to VAT. They benefit from an exemption based on Article 44 of the VAT Code. This means that, as a liberal professional, you don’t charge VAT to your customers, you can’t deduct VAT on your purchases, and you don’t need to file a quarterly VAT return.
Certain liberal professions may be partially subject to VAT. This mixed VAT liability applies if, in addition to your liberal profession, you carry out other activities that are subject to VAT (e.g. you provide training or sell products).
Liberal professions and e-invoicing
Electronic invoicing will be mandatory from 2026 for all VAT-registered businesses that send invoices to other businesses. This obligation does not apply to liberal professionals who are fully exempt from VAT.
For liberal professionals subject to mixed VAT, the situation is more nuanced:
- For your VAT-exempt activities, electronic invoicing is not mandatory.
- Do you send invoices to other businesses for your VAT-registered activities? In this case, starting in 2026, you’ll be required to send electronic invoices for these activities.
The e-invoicing obligation only applies to B2B transactions between businesses. Are you a self-employed liberal professional with mixed VAT liability? Do you only have private clients? In this case, you do not need to send electronic invoices.
In summary
- Liberal professions not subject to VAT do not have to send electronic invoices.
- If, in addition to your liberal profession, you carry out an activity that is subject to VAT and you invoice other businesses, you must send electronic invoices for those services.
- Are you fully liable for VAT and invoice Belgian businesses? In this case, electronic invoicing will become mandatory for you from 2026.
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