Belgium is taking a further step in the digitalization of its VAT system. On 18 July 2026, the Belgian Council of Ministers approved a preliminary draft law introducing an obligation to electronically report invoice data to the Belgian VAT administration. This builds on the mandatory structured B2B e-invoicing regime in force since 1 January 2026 and signals the next phase of Belgium’s digital VAT strategy.
Below, we outline the key elements based on what is already known today and what this means for your business.
Background
Since 1 January 2026, Belgian established and VAT-registered businesses are required to issue and receive structured electronic invoices for most domestic B2B transactions, in principle via the Peppol network (Peppol-BIS format). This mandatory e-invoicing regime laid the groundwork for the next phase of Belgium’s digital VAT compliance framework.
A new reporting obligation represents the logical next step by extending the use of structured e-invoice data for near real-time digital reporting and control purposes. The introduction of this new obligation also fits in the wider EU ViDA Digital Reporting Requirement (DRR) which will introduce mandatory structured e-invoicing and near real-time reporting for intra-EU transactions by 1 July 2030.
What is being proposed
On 18 July 2026, the Belgian Council of Ministers approved apreliminary draft lawintroducing an obligation for businesses to electronically report key invoice data to the Belgian VAT administration by 1 January 2028 (subject to confirmation).
The proposed digital real time reporting system is proposed to have the following key features:
- Faster access to invoice data: provide the Belgian tax administration with near real-time access to invoice data.
- Bi-directional reporting: both the supplier and the buyer will have to report the key invoice data in near real time.
- Annual sales list abolished: to reduce the compliance burden for businesses the annual client listing will be abolished for entities in scope of the real-time reporting obligation
It is important to note that this is a first legislative step and that the preliminary draft law is not publicly available. Further legislative steps—including advice from the Council of State and Data Protection Authority, final approval by the Council of Ministers, parliamentary approval, and implementing or royal decrees—are expected later this year and in the beginning of 2027.
Practical implications for businesses
Although the measure is not yet final, businesses should start considering the potential impact.
Key areas to focus on include:
- Reliable master & transactional data: Ensure that customer/supplier data, product/service codes and tax codes are accurate and consistent, as this data will feed directly into the authorities’ reporting and control systems.
- Review VAT treatment: As invoice data will be shared on a transactional level in near real-time, the correctness of the VAT treatment of the transaction will be key.
- System readiness: Assess and, where needed, adapt ERP and invoicing systems to ensure they can generate and transmit the required structured data reliably. This is especially relevant if the Peppol-opt out possibility was used.
- Cross-functional collaboration: Finance, Tax, and IT teams will need to work together on data quality, system readiness, and process changes. This is not purely a tax or legal matter—it is also an operational and IT project.
- Need for business analytics and controls: Enable risk-based and more efficient tax controls and fraud detection leveraging based on the structured invoice data.
- Early impact assessment: Given the short lead time, businesses are encouraged to start assessing the potential impact now, rather than waiting for the final legislation.
How PwC can help
PwC Belgium is closely monitoring this legislative development and will keep clients informed as further details—entry into force, scope, technical requirements, sanctions—are confirmed.
We invite you to reach out to your PwC contacts to:
- Discuss the potential impact on your business
- Assess your readiness (systems, data, and processes)
- Prepare an implementation roadmap and action plan
Contacts
For more information, please contact:
- Ellen Cortvriend Partner, PwC Belgium
- Brecht Van Petegem Director, PwC Belgium
- Sven Geenens Senior Manager, PwC Belgium
