Mandatory B2B e-invoicing in Belgium: Tolerance period announced

In this article, Antoine Druetz (EY Law) breaks down the Belgian B2B e-invoicing requirements and the recently announced tolerance period for NPOs.

As you know, from 1 January 2026, all Belgian business-to-business (B2B) invoices will be required to be issued and sent electronically in a structured format that enables automated processing. Importantly, not-for-profit organisations (NPOs) are not automatically exempt. Many will fall under the scope of this new obligation and must take action to ensure compliance.

The Belgian authorities have however recently announced that a tolerance period will apply during Q1 2026 in certain circumstances. If specific conditions are met during this period, no penalties will be imposed for certain breaches related to e-invoicing.

‘Timely and reasonable’ condition

The tolerance is only granted provided that the taxable person can demonstrate that it has made sufficient efforts to ensure the correct and timely application of e-invoicing. In such case, the taxable person will have the opportunity to comply with the e-invoicing mandate without a penalty. Taxable persons who did not so, will be encouraged to comply as soon as possible. A potential penalty will then be assessed on a case-by-case basis based on the concrete circumstances.

Importantly, this does not imply a delay in the go-live date; mandatory B2B e-invoicing still starts on 1 January 2026. Instead, the tolerance period reflects a pragmatic approach for taxable persons that are prepared on time but are still dealing with issues outside of their control.

What does this mean for NPO’s?

• Temporarily reduced tax exposure while organisations finalise their Belgian e-invoicing setup and collaborate with e-invoicing vendors.

• Potential need to manage multiple AR/AP processes from 2026, depending on the e-invoicing readiness of customers and suppliers.

• Planning ahead remains essential.

For your convenience, an English translation of the official communication can be found here: 

 E-invoicing: tolerance period for the first three months of 2026 | FPS Finance