Key takeaways
- The legal basis for B2B e-invoicing rests on two Belgian texts: the law of 6 February 2024 and the royal decree of 8 July 2025.
- The law inserts the obligation into the VAT Code (article 53, § 2bis); the royal decree sets its technical rules.
- The mandated format is a structured invoice compliant with the EN 16931 standard, in the Peppol BIS format, sent over the Peppol network.
- Directive 2014/55/EU covers public procurement (B2G); the ViDA package removed the need for a derogation for national mandates.
The legal basis for B2B e-invoicing, in brief
The obligation to issue structured e-invoices between businesses is not a mere administrative recommendation: it is a rule of tax law, anchored in precise texts. The legal basis for B2B e-invoicing in Belgium rests on two complementary layers: a law, which creates the obligation, and a royal decree, which governs its technical execution.
The first layer is the law of 6 February 2024, published in the Moniteur belge on 20 February 2024. The second is the royal decree of 8 July 2025, published in the Moniteur belge on 14 July 2025. On top of these two texts sits a European layer, made of the common EN 16931 standard and the recent evolution of EU VAT law.
This article places each text and shows how they fit together. For the concrete scope of the obligation, read Peppol in Belgium: the B2B mandate on 1 January 2026; for a step-by-step path to compliance, Getting ready for e-invoicing in 2026.
The law of 6 February 2024: the founding text
The founding text carries an explicit title: "law amending the Value Added Tax Code and the Income Tax Code 1992 as regards the introduction of the e-invoicing obligation". It does not create a new code: it amends two existing codes to write the obligation into them.
At the heart of the mechanism, the law inserts a new article 53, § 2bis into the VAT Code. It is this provision that requires a taxable person established in Belgium to issue a structured e-invoice to its counterparty for its B2B transactions, from 1 January 2026. The law also adds, in article 1, § 13 of the Code, a definition of the "structured e-invoice", so that the term used by the obligation carries a fixed legal meaning.
Finally, the law amends the Income Tax Code 1992 to support the transition with tax incentives, notably on the deductibility of costs linked to e-invoicing tools. The legal basis is therefore not only binding: it also provides an accompanying measure.
What the law of 6 February 2024 does
Creates the obligation in the VAT Code
New article 53, § 2bis: issuing a structured e-invoice in B2B from 1 January 2026.
Defines the structured e-invoice
Article 1, § 13 of the VAT Code: a fixed legal meaning for the term the obligation uses.
Amends the Income Tax Code 1992
A set of tax incentives supporting the adoption of e-invoicing tools.
The royal decree of 8 July 2025: the technical rules
A law that mandates a "structured e-invoice" does not, on its own, say which format to use. That is the role of the royal decree of 8 July 2025, which amends the VAT royal decrees to spell out how the obligation is carried out. Published in the Moniteur belge on 14 July 2025, it turns a principle into a verifiable technical requirement.
The decree requires a structured invoice compliant with the European EN 16931 standard, in the Peppol BIS format, sent by default over the Peppol network. In other words, the default frame is the one most businesses already know: Peppol for transport, EN 16931 and Peppol BIS for the content.
The text does leave room, however: the parties may agree between themselves on another format and another channel, on the condition that the chosen format complies with the EN 16931 standard. This flexibility does not call the obligation into question; it bears on the means, not on the principle.
How Belgian law fits with EU law
The most common confusion is to believe that the B2B obligation flows from Directive 2014/55/EU. It does not. That directive covers e-invoicing in public procurement (B2G) and was transposed separately. The obligation between businesses rests, instead, on the Belgian national law described above.
EU law still comes in on two counts. First, the EN 16931 standard — the common semantic model of the invoice in Europe — is the foundation that the Belgian legal basis makes mandatory. Second, mandating structured e-invoicing without the recipient's agreement previously required a derogation from Articles 218 and 232 of Directive 2006/112/EC. The ViDA package (Directive (EU) 2025/516), in force since 14 April 2025, now lets Member States mandate e-invoicing on their territory without requesting that derogation, which gave legal certainty to national mandates such as Belgium's.
| Directive 2014/55/EU (B2G) | Belgian B2B legal basis | |
|---|---|---|
| Covers public procurement | ||
| Covers business-to-business (B2B) transactions | ||
| Source: transposed EU law | ||
| Source: Belgian law and royal decree | ||
| Mandates the EN 16931 standard |
The timeline of the texts
The legal basis was not built in one go: it was assembled text after text, which is why the obligation could be known long before it took effect. Here are the legal milestones to remember.
- 1
Founding law
6 February 2024Law of 6 February 2024 amending the VAT Code and the Income Tax Code 1992.
- 2
Publication of the law
20 February 2024Appearance in the Moniteur belge, the starting point for legal certainty.
- 3
EU framework consolidated
14 April 2025Entry into force of the ViDA package (Directive (EU) 2025/516): no derogation to request.
- 4
Implementing decree
14 July 2025Royal decree of 8 July 2025 setting the format (EN 16931, Peppol BIS) and channel (Peppol).
- 5
Obligation takes effect
1 January 2026Issuing structured e-invoices becomes mandatory in B2B.
What the legal basis requires of your business
Put in practical terms, the legal basis comes down to a requirement of result: for its B2B transactions, a business established in Belgium must issue and receive structured e-invoices compliant with EN 16931, in the Peppol BIS format, over the Peppol network. A free-form PDF no longer suffices, and the obligation applies to receiving as much as to issuing.
The concrete consequence is about the choice of tool. Compliant software produces a valid file, checks it against the profile's rules and routes it, without your having to know the detail of the texts. Verifying that compliance is the first useful reflex in the face of a deadline that has, itself, already passed into law.
Invoicing that meets the legal basis, without touching the XML
YouInv generates your invoices compliant with EN 16931 in the Peppol BIS format, validates them and sends them over the Peppol network.
Further reading
- Peppol in Belgium: the B2B mandate on 1 January 2026: who is in scope and what stays out of it.
- ViDA: VAT in the Digital Age in Europe: the EU framework and its timeline to 2035.
- The EN 16931 standard explained: the common semantic model the legal basis makes mandatory.
The official sources are authoritative: the text of the law of 6 February 2024 (Justel, Moniteur belge), the SPF Finances e-invoicing portal and Directive (EU) 2025/516 on EUR-Lex.
What is the legal basis for B2B e-invoicing in Belgium?
The legal basis rests on the law of 6 February 2024, published in the Moniteur belge on 20 February 2024, which inserts the obligation into the VAT Code (article 53, § 2bis), and on the royal decree of 8 July 2025, which sets its technical rules (the EN 16931 standard, the Peppol BIS format, the Peppol network).
What does the law of 6 February 2024 provide?
The law of 6 February 2024 amends the VAT Code and the Income Tax Code 1992. It inserts article 53, § 2bis into the VAT Code, requiring taxable persons established in Belgium to issue a structured e-invoice for their B2B transactions from 1 January 2026, and a definition of the structured e-invoice in article 1, § 13.
What is the purpose of the royal decree of 8 July 2025?
The royal decree of 8 July 2025, published in the Moniteur belge on 14 July 2025, sets out how the obligation is implemented. It requires a structured invoice compliant with the EN 16931 standard, in the Peppol BIS format, sent by default over the Peppol network. The parties may agree on another format and channel, provided it complies with EN 16931.
Is Directive 2014/55/EU the legal basis for the B2B obligation?
No. Directive 2014/55/EU concerns e-invoicing in public procurement (B2G). The Belgian B2B obligation rests on national law (the law of 6 February 2024 and the royal decree of 8 July 2025). EU law also plays a part through the EN 16931 standard and the ViDA package.
Was an EU derogation needed to mandate B2B e-invoicing?
Mandating structured e-invoicing without the recipient's agreement previously required a derogation from Articles 218 and 232 of Directive 2006/112/EC. The ViDA package (Directive (EU) 2025/516), in force since 14 April 2025, now lets Member States mandate e-invoicing on their territory without requesting that derogation.
