New guidance clarifies invoice rejection, reverse charge treatment and delivery monitoring
Belgium has published a significant operational update to its mandatory 2026 B2B e-invoicing regime, refreshing the official Frequently Asked Questions for the first time since the 1 January go-live.
The revised guidance from FPS BOSA introduces seven new questions and updates two existing entries, focusing heavily on AP/AR processing controls and Peppol network management.
Peppol delivery delays acknowledged
Belgium has now formally confirmed that Peppol does not guarantee real-time invoice transmission. Delays may arise between access points, ERP integrations and internal processing systems. Businesses are advised to investigate invoices delayed by more than one working day with their software provider or Peppol access point.
Reverse charge invoice validation softened
Accounts payable teams should no longer reject invoices solely because the Article 20 §3 wording is missing, provided “reverse charge” wording remains present elsewhere on the invoice. The update effectively moves these cases from hard rejection into warning or supplier follow-up processes.
New rejection process for incorrect recipients
Businesses receiving invoices not intended for them must reject them using a Peppol Invoice Response with rejection code “RE”. Suppliers issuing invoices to the wrong recipient must still include the transaction in VAT reporting before correcting it through a credit note.
Self-billing registration clarified
Belgium also confirmed that suppliers, rather than customers, must be registered within Peppol to receive self-billing invoice document types. Existing contractual acceptance obligations between the parties remain unchanged.
The update highlights how e-invoicing compliance is increasingly shifting from legal interpretation towards operational execution. Businesses should now review AP validation rules, invoice rejection workflows, Peppol delivery monitoring and ERP master data controls to ensure ongoing compliance with Belgium’s evolving digital VAT framework.
