Belgium is extending invoice digitalisation toward reporting
Deloitte Belgium reported that the Council of Ministers approved a preliminary draft law on 18 July that would amend the VAT Code and introduce electronic reporting of invoice data. The proposal builds on Belgium’s structured business-to-business e-invoicing obligation, applicable since 1 January 2026, and would move selected invoice information toward near-real-time transmission to the tax authorities.
The envisaged start date is 1 January 2028. That may sound distant, but ERP, tax, master-data, and integration changes take time to design and test. Businesses should not implement rules that are not yet final. They can, however, strengthen the data and process foundations that will be necessary under almost any final design.
What happened
Deloitte describes three central features. First, certain mandatory invoice data would be transmitted electronically in near real time. Second, reporting would be bilateral: both the supplier or service provider and the customer would report. Third, the annual client listing would be abolished for taxable persons subject to the e-reporting obligation.
The stated objectives include more reliable digital data flows, faster information for the tax authorities, improved risk analysis, action against fraud, and more efficient audits. The practical scope, data fields, technical modalities, and final effective rules remain to be defined.
This is not enacted law. The preliminary draft was sent to the Data Protection Authority and the Council of State for advice. Deloitte notes that it would then require a second reading by the Council of Ministers and adoption by the Chamber of Representatives. The start date and details remain subject to the legislative process and implementing royal decree.
Why it matters for growing businesses
Near-real-time reporting changes the cost of poor data. Today, a missing VAT number, inconsistent customer record, incorrect tax code, or late credit note may be corrected during a periodic close. When invoice data is transmitted quickly and matched bilaterally, errors can become visible to counterparties and authorities sooner. The response process must therefore move closer to the transaction.
Bilateral reporting also makes reconciliation more important. The supplier and customer need compatible references, dates, amounts, VAT treatment, and document relationships. An ERP should preserve the link between invoice, credit note, order, receipt, customer, and Peppol message. Manual rekeying and duplicate master records increase the chance of mismatches.
This is not only a tax-team project. Sales determines customer data, purchasing controls supplier onboarding, operations confirm delivery, finance manages postings, IT supports integration, and management decides ownership. A narrow interface added at the deadline cannot compensate for weak upstream processes.
Build a readiness backlog without overcommitting
Separate no-regret improvements from proposal-dependent decisions. No-regret work includes deduplicating customers and suppliers, validating VAT identifiers, documenting tax determination, upgrading supported ERP modules, monitoring Peppol flows, and creating an exception owner. Decisions about exact payloads, timing, exclusions, or storage should wait for confirmed law and technical specifications.
Create a requirements register that labels every item as proposed, confirmed, or implemented. Attach the source and review date. This prevents project teams from treating commentary as final law and makes later changes easier to manage.
Practical action checklist
- Confirm which Belgian entities and transaction flows are already subject to structured e-invoicing.
- Inventory invoice creation outside the ERP, including portals, spreadsheets, point-of-sale, and subsidiaries.
- Deduplicate customer and supplier records and validate VAT numbers, addresses, currencies, and payment terms.
- Document tax-code selection for domestic, EU, export, exempt, reverse-charge, and credit-note scenarios.
- Preserve structured references between orders, deliveries, invoices, credit notes, and Peppol messages.
- Monitor rejected or delayed e-invoices and assign an owner and resolution deadline to each exception.
- Assess whether the current Odoo version, localization, Peppol provider, and integrations can support future reporting.
- Design reconciliation between ERP totals, transmitted records, counterparty information, and VAT returns.
- Keep a change-controlled register of legislative and technical updates through final adoption.
- Budget for testing with customers, suppliers, advisers, and providers well before the envisaged 2028 date.
How VDS Consultoria can help
VDS Consultoria helps Belgian and cross-border businesses prepare Odoo for digital invoicing and reporting. We can assess master data, map invoice flows, review localization and integration dependencies, strengthen exception management, and build reconciliation dashboards. We work with the company’s tax and legal advisers so technical implementation follows confirmed requirements.
This article summarizes a preliminary proposal and is not tax or legal advice. The best action today is not to guess the final payload. It is to make the ERP data accurate, the Peppol flow observable, and every invoice exception owned and traceable.
Source
Deloitte Belgium, “Belgium to introduce near-real-time e-reporting of invoicing data,” July 27, 2026: https://www.deloitte.com/be/en/services/tax/blogs/belgium-to-introduce-near-real-time-e-reporting-of-invoicing-data.html