New E-Invoicing rules for non-profits in Belgium from 1 January 2026: Are You Ready?

In this article by Antoine Druetz, Sofie Van Doninck and Elise Theys from our parters at EY Law, they unpack Belgium’s upcoming mandatory e-invoicing reform, taking effect on 1 January 2026. The authors explain what this means for non-profit organisations, who may also fall under the new rules, and outline the key steps needed to ensure compliance and avoid penalties.

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. This change forms part of a broader effort by the Belgian government to modernise VAT administration and combat fraud.

Importantly, non-profit organisations (NPOs) are not automatically exempt. Many will fall under the scope of this new obligation and must take action now to ensure compliance.

Who must comply?

Your organisation must issue and receive structured electronic invoices if the following three conditions are met:

1. VAT status: Your association is VAT-registered in Belgium (this includes those under the small enterprises regime) and does not exclusively perform VAT-exempt activities as listed under Article 44 of the Belgian VAT Code;

2. Your customer: The invoice is issued to another VAT-registered entity in Belgium, which is required to provide its Belgian VAT number, and is also not exclusively performing VAT-exempt activities; and

3. Local transactions: The transaction is a local supply of goods or services in Belgium, which is not VAT-exempt under Article 44.

If all three conditions apply, your association must transition to structured electronic invoicing by 1 January 2026.

What format is required?

Under the Royal Decree of 14 July 2025, Peppol BIS has been confirmed as the standard format for structured e-invoices in Belgium. While other formats may be used by mutual agreement, they must comply with EU e-invoicing standards, and your organisation must still be technically capable of issuing and receiving Peppol BIS invoices.

This means that any NPO falling under the new rules will need access to the Peppol network, even if using alternative formats.

Penalties for non-compliance

Organisations that fail to meet the technical requirements for structured e-invoicing face significant penalties:

• First infraction: €1,500

• Second infraction: €3,000

• Subsequent infractions: €5,000

  
  

  (Only infractions occurring at least three months apart count as subsequent violations)

These are in addition to existing VAT penalties, which can amount to 60% or even 100% of the VAT due for irregular or missing invoices.

What should non-profits do now?

With the deadline fast approaching, it is crucial for NPOs to:

• Assess their VAT status and invoicing practices;

• Determine if they fall within scope; and

• Implement the necessary technical solutions to issue and receive structured e-invoices in the Peppol BIS format.

Even organisations with limited activities may be affected. Early action will help avoid disruption and financial penalties in 2026.

Final word

While the transition to mandatory e-invoicing may feel daunting, it also presents an opportunity for non-profits to modernise administrative processes, improve transparency, and ensure full compliance with VAT obligations.

In case of doubt, seek professional advice to confirm your organisation’s obligations and begin preparations without delay.