Receiving Is an Obligation Too: Deduction and Fines Since 1 April 2026

Every briefing on this mandate has been written from the sending side. The exposure now sitting in client files is on the other one — and it is quieter, because a receiving failure produces no error anyone sees.

This briefing reflects the FAQ published by the FPS Finance at efactuur.belgium.be as live on 23 August 2026. That page carries no visible last-modified date, so read the dating of this piece as the dating of that reading.

The dates, and the one that is not a deadline

The Belgian B2B structured e-invoicing obligation and the Royal Decree of 8 July 2025 (BS 14 July 2025, numac 2025005169) both took effect on 1 January 2026. A general tolerance meant no penalties were applied through 31 March 2026; from 1 April 2026 they are possible.

A second tolerance existed, and it is the one most often quoted back at you: it covered self-billing arrangements, and it ran to 30 June 2026. It has closed, and it was never a general reprieve. If a client's file is planned around 30 June, it is planned around a carve-out that never applied to their situation.

The operative pair is 1 January and 1 April 2026. There is no third date to wait for.

Deduction: what the FAQ says, and what it does not

Per the FAQ at efactuur.belgium.be, for a transaction covered by the Belgian B2B e-invoicing obligation, the right to deduct requires holding a structured electronic invoice within the meaning of article 3, § 1, 1° of Royal Decree no. 3. A supplier's PDF or paper invoice is, in principle, not a document supporting deduction for such a transaction.

Two qualifiers carry that sentence, and dropping either one turns a correct statement into a misleading one.

"Covered by the obligation." Not every purchase invoice in a Belgian client file is in scope, and the scope narrowed during 2026 — see the next section. A PDF from a non-Belgian-established supplier is not a defect. Write the qualifier into every note you send a client on this, or you will spend the following week explaining why their German software subscription is fine.

"In principle." The VAT Commentary (Book III) holds that where the material conditions of deduction are met, the right cannot be refused on a formal defect alone. That is settled Belgian doctrine and it is not displaced by the FAQ's wording. So the correct handling of an in-scope supplier PDF is a compliance flag to chase, not a deduction written off. Telling a client they have lost the VAT is both wrong and expensive to walk back.

The Act of 10 February 2026 kept the lawful PDF alive

The Act of 10 February 2026 (BS 20 February 2026), commented in circular 2026/C/43, inserted a technical-impossibility carve-out into article 53, § 2bis of the VAT Code: where the recipient cannot technically receive a structured electronic invoice, the supplier is not obliged to issue one and must issue an ordinary invoice instead. An ordinary invoice is a regular invoice, and a regular invoice supports deduction in the ordinary way.

The same Act removed the issuing obligation for suppliers not established in Belgium who invoice a Belgian-identified customer.

Two consequences for the file:

• A lawfully issued PDF still exists in 2026. Any blanket rule of the form "a PDF received after 1 January 2026 is a problem" will generate false positives across every client with foreign suppliers, which is most of them.
• The relief is drafted around the recipient's technical inability, but it discharges the supplier. Read from the other end, a client who is registered on Peppol and receiving is not the addressee of that relief — and a client who is not registered at all is still holding the obligation to have the means, whatever their suppliers do about it. The Act protects the issuer facing a non-ready counterparty. It writes no equivalent protection for the non-ready recipient.

The fine attaches to the means, not to the invoice

The Royal Decree of 8 July 2025 sets €1,500 / €3,000 / €5,000 for lacking the technical means to issue and receive structured electronic invoices.

Read the drafting carefully before you quote a figure to a client. It is conjunctive — uit te reiken en te ontvangen / d'émettre et de recevoir — and the Report to the King describes the offence as a taxable person who would not have those means at all (in het geheel niet zou beschikken), sanctioned by analogy with the failure to hold a compliant cash register.

So: there is no separate, established €1,500 fine for being unable to receive while being able to send. Whether a receive-only gap is punishable on its own is arguable, not settled. That is a better sentence to give a client than a bluff, and it is also the more useful one — it tells them the real risk is being found with no capability at all, which is exactly the client who has never looked.

These are non-proportional fiscal fines under Royal Decree no. 44, and they remain subject to the reduction scales in article 3 of that decree. Good faith and a first infringement are arguments that exist.

The three-month reset is a real defence

A subsequent infringement counts as such only where it is established at least three months after the previous one. Escalation therefore cannot be stacked inside a single audit.

Diary the date of any finding on the client file. The three-month clock is the difference between a bounded incident and a compounding one, and it is not something the client will track.

Why a receiving endpoint fails silently

Belgium identifies Peppol participants under scheme 0208 — the enterprise number (KBO/BCE). Legacy registration under 9925 (BE:VAT) alone is a leading real-world cause of invoices that are never delivered and never bounced.

That failure mode is the reason this section exists. There is no rejection, no error returned to the sender, and no notification to the recipient. The invoice simply does not arrive, and the first symptom is a payment reminder from a supplier for a document nobody in the client's office has ever seen.

The practical rule for both ends: a sender should look up and confirm the recipient's identifier rather than assume it. For your own clients, confirm which identifier they are actually registered under, and confirm it by lookup rather than by asking.

Sending and receiving are different capabilities

Do not infer receive-readiness from the fact that a client's outgoing invoices leave. They are separate registrations with separate routing, and outbound success carries no information about inbound delivery. This inference is, in practice, the most common reason a client believes they are ready.

The test that settles it is a live receive-side test to each client's Peppol identifier, confirmed at the destination — the document present where the books are kept, not a transmission screen reporting no error.

The client-file work order

1. List the client's Peppol identifier and confirm the scheme it is registered under. Confirm by lookup.
2. Run a live receive test into each client's environment and confirm arrival at the destination, not at the access point.
3. Pull supplier PDFs booked since 1 January 2026 and split them: out of scope (non-Belgian-established supplier, or transaction not covered) versus in scope.
4. For the in-scope ones, chase the structured invoice and record the request. This is a formal-condition file to close, not a deduction to reverse — but it should be closed while the counterparty still remembers the transaction.
5. Where a technical impossibility was relied on, note on what basis and from when. The carve-out is an exception being invoked, and an exception that nobody documented is an exception nobody can show.
6. If a finding has been made, diary it and diary three months out.

What to tell a client, in one sentence

Their outgoing invoices leaving tells them nothing about the invoices addressed to them; the penalty is for having no capability rather than for any single document; and a supplier PDF on a covered transaction is a formal condition to repair, not money lost.