Belgian VAT e-reporting from 2028: what the draft law says

On 18 July 2026 the Council of Ministers approved a preliminary draft law amending the VAT Code: near-real-time electronic reporting of mandatory invoice data by both supplier and customer, and abolition of the annual list of taxable customers for those subject to it. It is not law. The draft targets 1 January 2028, conditional on an EU authorisation. The 2026 client listing remains due by 31 March 2027.

What is the instrument, and how far has it got?

Voorontwerp van wet tot wijziging van het Wetboek van de belasting over de toegevoegde waarde wat de invoering van de verplichting tot elektronische rapportering en de opheffing van de verplichting tot indiening van de jaarlijkse lijst van belastingplichtige afnemers betreft. Proposed by Jan Jambon, Minister of Finance.

The ITAA expects the law in autumn 2026 and the implementing Royal Decree in early 2027. That is a professional body's expectation, not a government timetable.

What does the draft change in the VAT Code?

The press release gives the principle. The detail below comes from the HRZKMO opinion, which describes the draft and its explanatory memorandum as submitted for advice in June 2026. The approved text may differ.

• Art. 53quinquies VAT Code is rewritten. New §1: the supplier reports data from the structured e-invoices, or equivalent documents, it issues. New §2: the customer reports the same data for the same transactions, as purchases. The annual list of taxable customers is repealed for those within scope.
• Scope follows e-invoicing (art. 53, §2bis). Taxpayers carrying out only transactions exempt under art. 44 stay out, as they were for the listing.
• Art. 2 of the draft extends e-invoicing to taxpayers not established in Belgium but VAT-identified here, so that e-invoicing, e-reporting and the listing cover the same population.
• VAT units: the obligation rests on the members, as it does for the listing today.
• Flat-rate farmers (art. 57): excluded for supplies under that scheme; the purchaser reports from its self-billed document.
• Flat-rate scheme (art. 56): ends by 1 January 2028 (art. 56, §7), so no carve-out is needed.
• Tolerances: the tolerance in no. 11 of circular 3/1986 (invoice amount of €250 or less) and the one in no. 20 fall away from 1 January 2028 for transactions within scope. No exceptions by type of goods or services.
• Granularity: from aggregated annual amounts per customer to data per invoice.
• Access: a taxpayer could request, through the MyMinfin contact form, all data reported by and about it, with an answer within 30 days. The HRZKMO asks for immediate access instead.
• No accounting data: the HRZKMO stresses that the system is meant to process invoice data only.

When would it enter into force?

1 January 2028 in the draft, subject to an EU Council authorisation under art. 395 of Directive 2006/112/EC for the extension of e-invoicing to non-established, Belgium-registered taxpayers. The authorisation would only be needed until 1 July 2030, when ViDA lets Member States impose this themselves.

If it is not granted, the FPS Finance has put three options forward, as the HRZKMO reports them:

1. keep a reduced annual listing for supplies to non-established, Belgium-registered customers;
2. require e-reporting of the non-structured invoices issued to them;
3. postpone the abolition of the client listing to 1 July 2030.

The HRZKMO calls option 3 the least appropriate and proposes a fourth: no extra reporting for invoices that cannot be issued as structured e-invoices, with targeted audits instead. Which option the government keeps is not public.

Which client listing is the last?

Not settled. The listing for 2026 is due by 31 March 2027 under the current rules. Whether a listing for 2027, due in 2028, is still filed, and by whom, depends on transitional provisions not yet published and on the EU authorisation. Do not tell clients that the 2026 listing is the last.

What is left to the Royal Decree?

The data to be reported, the deadlines, the method and the electronic address the data goes to, including the special cases (members of a VAT unit, purchases from flat-rate farmers). Preparatory work in the BEG forum, as reported by the HRZKMO, aims to:

• align deadlines with art. 263 of the VAT Directive as amended by ViDA: supplier when the invoice is issued, customer within five days of receipt, five days for self-billing;
• use the ViDA Tax Data Document as the data set, in an EN 16931 format;
• cover the exceptions: customer without an enterprise number, customer unable to receive e-invoices, invoicing by a third party, credit notes, invoices alongside a cash-register (GKS) ticket, a wrong recipient.

Neither the press release nor the HRZKMO opinion names Peppol or a "fifth corner". The ITAA describes reporting through the same Peppol network used for e-invoicing, and vendor commentary calls it a five-corner model. Both are readings of the design, not of a text.

How does it relate to ViDA?

ViDA (Directive (EU) 2025/516) introduces digital reporting requirements for intra-EU B2B transactions from 1 July 2030. The Belgian draft brings domestic reporting forward and is designed to fit the new arts. 271bis and 271ter of the VAT Directive, so that it need not be rebuilt in 2030. See ViDA and Belgian businesses.

What to tell clients now

• No legal obligation yet. The 2026 listing is filed as usual, by 31 March 2027.
• Receiving matters as much as sending, since the customer would report too. Check that receiving works for every client, including those who mostly buy. Background: what Peppol e-invoicing is and the 2026 Peppol guide.
• Clean master data: enterprise and VAT numbers, VAT rates and exemption references, credit notes instead of edited invoices. Mismatches between supplier and customer reports are what the system is built to find.
• The open questions sit with clients who deal with non-established, Belgium-registered counterparties and with members of VAT units.