Key takeaways
- Self-billing lets the customer draw up the invoice in the name and on behalf of the supplier.
- The VAT Directive allows it under two conditions: a prior agreement and a procedure for the acceptance of each invoice.
- The invoice must carry the word "Self-billing", on top of the usual mandatory details.
- The supplier stays liable for the VAT and responsible for the invoice, even though the customer writes it.
Self-billing, when the customer issues the invoice
In the usual commercial relationship, the supplier invoices the customer. Self-billing reverses that reflex: the customer draws up the invoice, in the name and on behalf of the supplier, for the goods or services the supplier delivers. The arrangement is perfectly legal, but it is framed: you cannot self-bill freely.
The benefit is concrete. When a business receives regular deliveries from many suppliers, or knows the exact quantities received better than they do, letting the customer produce the invoice makes the data more reliable and smooths processing. Whole sectors work this way: agriculture, subcontracting, platforms that pay a multitude of providers.
This article sets out the legal framework of self-billing in Belgium: the two conditions to meet, the mandatory mention on the invoice, the question of responsibility, and what the Peppol mandate of 1 January 2026 changes.
The two conditions set by the VAT Directive
The European basis is Article 224 of Directive 2006/112/EC. It allows an invoice to be drawn up by the customer "where there is a prior agreement between the two parties and provided that a procedure exists for the acceptance of each invoice by the taxable person supplying the goods or services". In Belgium, this framework is transposed in Article 53, § 2 of the VAT Code and detailed by circular AGFisc No. 53/2013 of the FPS Finance.
Two cumulative conditions follow, and self-billing is regular only if both are met.
The two conditions for self-billing
A prior agreement between the parties
Customer and supplier agree, before any transaction, that the former will invoice on behalf of the latter. Since the 2013 circular the form is free — verbal or written — but a written agreement is strongly recommended for an audit.
A procedure for the acceptance of each invoice
The supplier must be able to accept (or dispute) each invoice issued in their name. Silence can count as acceptance if the agreement says so, but the mechanism must exist and be traceable.
The prior agreement sets the scope: which transactions, for which period, on which terms. It is what must be produced in an audit to prove the customer was entitled to invoice. The acceptance procedure, in turn, ensures the supplier keeps control over what is issued in their name: an invoice they dispute does not take effect.
The responsibility stays with the supplier
This is the point most often misunderstood. Self-billing shifts who writes the invoice, not the tax responsibility. The supplier remains the person liable for the VAT and responsible for the invoice towards the tax authority, even though it was their customer who drafted it.
The consequence is direct: if the customer applies a wrong VAT rate, an incorrect base or a missing detail, it is the supplier who will have to correct the situation with the authority. Self-billing a supplier relieves them of nothing; on the contrary, it obliges them to check what is issued in their name — which is exactly what the acceptance procedure is for.
| Classic invoicing | Self-billing | |
|---|---|---|
| Who drafts the invoice | The supplier | The customer |
| Prior agreement required | ||
| Acceptance procedure required | ||
| "Self-billing" mention on the invoice | ||
| Person liable for VAT | The supplier | The supplier |
The "Self-billing" mention and the other mandatory details
A self-billed invoice is an invoice like any other: it must carry all the mandatory details of a Belgian invoice required by Royal Decree No. 1 of 29 December 1992. Identity and VAT number of both parties, date, sequential number, description, taxable base, VAT rate and amount: nothing is lightened.
One specific mention is added to that list. Directive 2006/112/EC requires every invoice drawn up by the customer to carry the word "Self-billing" ("Autofacturation" in French). It signals without ambiguity that the invoice was issued by the customer, on behalf of the supplier, and not by the supplier themselves.
Self-billing and Peppol: the B2B mandate on 1 January 2026
Since 1 January 2026, structured electronic invoicing has been mandatory between VAT-registered businesses in Belgium, over the Peppol network. That obligation makes no exception for self-billing: an invoice drawn up by the customer in B2B must also travel in the structured electronic format, no longer as a PDF or on paper.
In practice, it is the customer's system — the one issuing — that generates the invoice in the Peppol BIS Billing 3.0 format and sends it through an access point, while carrying the "Self-billing" mention and honouring the prior agreement with the supplier. The 0208 scheme, which identifies a Belgian business by its enterprise number, handles routing as for any invoice. For the calendar and scope of the obligation, see Peppol in Belgium: the B2B mandate on 1 January 2026.
cumulative conditions
prior agreement and acceptance procedure
European basis
Directive 2006/112/EC
Peppol B2B mandate
applies to self-billing too
When self-billing makes sense
Self-billing is not a regime you adopt by default: it answers precise situations where the customer is best placed to draw up the invoice. That is the case when they know, better than the supplier, the quantities or services actually provided — regular deliveries, usage-metered services, payment of a large number of small suppliers by a single platform.
In those cases, centralising issuance on the customer side cuts re-keying errors and shortens the invoicing cycle. The price is rigour: a clear prior agreement, an acceptance procedure that works, the correct mention on every document, and a tool able to produce these invoices in the right format. That is the first thing to check before starting.
Compliant invoices, whether you issue or receive
YouInv generates and sends your invoices in the Peppol BIS Billing 3.0 format, with the mandatory details, in a few clicks.
Further reading
- Mandatory details of a Belgian invoice: the full list to include, self-billing among them.
- Peppol in Belgium: the B2B mandate on 1 January 2026: who is in scope and from when.
- E-invoicing for the self-employed and small structures: the framework for the smallest businesses.
The reference source is authoritative: Article 224 of Directive 2006/112/EC and circular AGFisc No. 53/2013 of the FPS Finance.
What is self-billing?
Self-billing is the arrangement where the customer draws up the invoice, in the name and on behalf of the supplier, for the goods or services the supplier delivers. The VAT Directive allows it provided there is a prior agreement between the two parties and a procedure for the acceptance of each invoice by the supplier.
What are the two conditions for self-billing?
Article 224 of Directive 2006/112/EC sets two cumulative conditions: a prior agreement between the customer and the supplier, and a procedure for the acceptance of each invoice by the supplier who delivers the goods or services. In Belgium this framework is set out in Article 53, § 2 of the VAT Code and detailed by circular AGFisc No. 53/2013.
Does the self-billing agreement have to be in writing?
Circular AGFisc No. 53/2013 leaves the form of the agreement free: it can be verbal or written. A written agreement is strongly recommended, however, because it is what must be produced in a tax audit to prove that the prior-agreement condition is met.
What mention must appear on a self-billed invoice?
An invoice issued by the customer must carry the word "Self-billing" ("Autofacturation" in French), required by Directive 2006/112/EC. It states clearly that the invoice was drawn up by the customer and not by the supplier, on top of the usual mandatory invoice details.
Who stays responsible for VAT under self-billing?
The supplier remains the person liable for the VAT and responsible for the invoice towards the tax authority, even though the customer drafts it. If a wrong rate is applied, it is the supplier who must correct the situation. Self-billing shifts who writes the invoice, not the tax responsibility.
