Peppol for VAT franchisees and VAT-exempt businesses: What you need to know

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As electronic invoicing becomes mandatory in more EU countries, it is important for businesses in Belgium to understand the Peppol e-invoicing requirements. Peppol (Pan-European Public Procurement On-Line) is a system that facilitates electronic invoicing in a standardized format across Europe.

In this article, we explain when you need to use Peppol for invoicing in Belgium, who is required to comply, and when you don’t need to.

📌 When is e-invoicing via Peppol mandatory?

1. From January 1, 2026:

   • All VAT-registered businesses in Belgium must use Peppol or an equivalent electronic invoicing format (compliant with the European standard EN 16931) when invoicing other businesses (B2B) within Belgium.

   • This means if you are a VAT-registered business in Belgium and issue invoices to another business in the country, Peppol will be mandatory from this date onwards.

2. For Invoices to the government (B2G):

   • Starting March 1, 2024, all invoices to Belgian public authorities for contracts worth €3,000 or more (excluding VAT) must be sent electronically via Peppol or related networks. This applies to new contracts from that date.

   • Some federal authorities will also require electronic invoicing for contracts below €3,000, effective from March 1, 2024.

3. Exemption for B2C (Business to Consumer):

   • If your business invoices private individuals (B2C), you are not required to use Peppol. The Peppol requirement only applies to B2B and B2G transactions.

4. Non-established businesses in Belgium:

   • Businesses without a fixed establishment in Belgium are currently not required to comply with the receiving obligation, according to the current interpretation.

✅ When are self-employed individuals exempt from VAT?

In Belgium, self-employed individuals (and small businesses) can be exempt from VAT under certain conditions, offering a simplified process with fewer administrative obligations. Key points:

• VAT franchisees: If your annual turnover in Belgium does not exceed €25,000 (excluding VAT), you are eligible for VAT exemption. This exemption applies regardless of your business form (sole proprietorship, company, etc.), as long as you meet the conditions.

• Advantages: No need to charge VAT, and no periodic VAT returns to submit.

• Disadvantages: You cannot claim VAT back on business expenses.

• Exceptions: Certain transactions or sectors are excluded or have specific rules (e.g., exempt transactions under Article 44 of the VAT law or specific forfait regimes).

⚠️ When must VAT-exempt self-employed individuals still use Peppol for e-invoicing?

The obligation to use Peppol for e-invoicing does not solely depend on VAT exemption but on whether the invoice is addressed to another business (B2B), in Belgium, and whether the transaction is taxable.

Important criteria for e-invoicing obligation:

• The invoice must come from a VAT-registered entity in Belgium performing a taxable supply within Belgium.

• The customer/recipient must be another VAT-registered entity (B2B) or a business based in Belgium.

• The transaction must be within Belgium and subject to VAT (not exempt under Article 44 of the VAT law).

• Deadline: e-Invoicing becomes mandatory for B2B transactions in Belgium starting January 1, 2026.

A VAT-exempt self-employed individual with a turnover of less than €25,000 may still be required to use Peppol for B2B invoicing if the transaction is taxable and within Belgium.

Who is exempt from Peppol E-Invoicing?

Certain businesses and organizations are exempt from using Peppol:

1. Non-established businesses:

   • Businesses without a fixed establishment in Belgium are not required to follow the Peppol e-invoicing rules for receiving invoices.

2. VAT-Exempt businesses:

   • VAT Franchisees with a turnover of less than €25,000 per year, or businesses that carry out fully VAT-exempt activities (such as medical services under Article 44 of the Belgian VAT Code), are not required to use Peppol.

3. Bankrupt businesses:

   • Businesses that are bankrupt are exempt from the Peppol requirements.

   Examples to make it clear

   Here are some examples of different types of businesses and whether they are required to use Peppol:

   1. Sarah, a photographer:

      • Sarah has a turnover under €25,000 and invoices private clients (B2C). She does not need to use Peppol.

   2. Tom, a consultant:

      • Tom has a turnover under €25,000 but invoices a Belgian business (B2B). He must use Peppol starting January 1, 2026.

   3. Laura, a doctor:

      • Laura provides exempt medical services and has a turnover under €25,000. She does not need to use Peppol.

📋 Summary in a table: e-invoicing requirements

Practical examples:

1. If you're self-employed with turnover under €25,000 and invoice individuals (B2C): No obligation to use Peppol. Peppol is not required for transactions involving consumers.

2. If you're self-employed with turnover under €25,000 and invoice a business (B2B) for taxable activities: You must use Peppol starting January 1, 2026. Even with a turnover under €25,000, if the transaction is taxable and you're invoicing a business, Peppol is required.
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3. If you're self-employed with turnover under €25,000 and invoice a business (B2B) for exempt services (e.g., medical services under Article 44): No obligation to use Peppol. Exempt transactions under Article 44 (such as medical or educational services) do not require Peppol, even if you are invoicing a business.

4. If you're self-employed with turnover over €25,000 and invoice a VAT-registered business (B2B): You must use Peppol starting January 1, 2026. If your turnover is over €25,000 and you are invoicing a VAT-registered business, Peppol is required for both sending and receiving invoices.

🔍 Final thoughts:

Understanding when Peppol e-invoicing applies is crucial for ensuring compliance and avoiding penalties. For self-employed individuals and businesses in Belgium, the key factors are whether you're VAT-registered, whether the transaction is taxable, and whether it involves another VAT-registered business.

Make sure to prepare for the mandatory transition to Peppol in 2026, and consult a tax advisor if you're uncertain about how this applies to your specific situation.

Author - Valesca Wilms

As content marketing lead at Accountable Belgium, Valesca writes about freelancing, self-employment, and taxes based on her own experience as a freelancer.

Who is Valesca ?