Peppol invoicing for contractors: reverse charge and 6% VAT

Since 1 January 2026, a construction invoice to a Belgian business that files periodic VAT returns goes over Peppol as a structured invoice. Under the reverse charge it carries no VAT, uses VAT category code AE, and must contain the full legal clause that starts "Verlegging van heffing" / "Autoliquidation". A renovation invoiced to a private homeowner at 6% is outside the Peppol obligation, but it needs its own clause too.

On €10,000 of works, that is €10,000 with no VAT to a main contractor, or €10,600 at 6% to a homeowner. The rest of this briefing is how to get each invoice right.

Which of my invoices have to go over Peppol?

Every invoice to a Belgian business liable for VAT. Since 1 January 2026 these must be structured electronic invoices, and Peppol is the default network for them. Invoices to private persons for their own use are excluded. If Peppol itself is new to you, start with what Peppol e-invoicing is and the setup checklist.

For a contractor, the split usually looks like this:

When does the reverse charge apply?

When you carry out works on a building (building, renovating, repairing, fitting out and similar work) for a client who is a taxable person required to file periodic VAT returns in Belgium. The client then pays the VAT instead of you (art. 51, §2, 5° of the VAT Code and art. 20 of Royal Decree no. 1).

In practice:

• you invoice without VAT;
• the client declares the VAT in its own periodic VAT return and, if it is entitled to, deducts it in the same return.

The classic case is a subcontractor invoicing a main contractor. It also covers any contractor working for a company, for example renovating its office.

A client that has a Belgian VAT number but does not file periodic returns has to tell you so when it gives you that number. You then charge VAT the normal way.

What must a reverse-charge invoice contain on Peppol?

The legal clause. Since 1 January 2023, writing "btw verlegd" is not enough. The invoice states no VAT rate and no VAT amount, and carries this text (Dutch and French versions as published in the Belgian Official Gazette):

> Verlegging van heffing. Bij gebrek aan schriftelijke betwisting binnen een termijn van één maand na de ontvangst van de factuur, wordt de afnemer geacht te erkennen dat hij een belastingplichtige is gehouden tot de indiening van periodieke aangiften. Als die voorwaarde niet vervuld is, is de afnemer ten aanzien van die voorwaarde aansprakelijk voor de betaling van de verschuldigde belasting, interesten en geldboeten.

> Autoliquidation : En l'absence de contestation par écrit, dans un délai d'un mois à compter de la réception de la facture, le client est présumé reconnaître qu'il est un assujetti tenu au dépôt de déclarations périodiques. Si cette condition n'est pas remplie, le client endossera, par rapport à cette condition, la responsabilité quant au paiement de la taxe, des intérêts et des amendes dus.

In short: if the client does not object in writing within a month, it is taken to confirm that it files periodic returns, and if it does not, the VAT, interest and fines are its problem, not yours.

The structured data. In the Peppol invoice, the lines carry VAT category code AE (reverse charge), a VAT rate of 0 and a VAT amount of 0. Your VAT number and the client's VAT number must both be present: the Peppol validation rules treat a missing one as a fatal error, so the invoice will not pass.

Where the clause goes. The official e-invoicing FAQ says these extended VAT clauses go in a note: the general invoice note, and the VAT exemption reason text.

If the clause is missing, the FAQ says the client should not reject an invoice that does say "reverse charge". The risk sits with you: without the clause, the shift of liability to the client does not take effect.

And a renovation for a private homeowner at 6%?

No Peppol obligation: the client is a private person having work done for their own use. A PDF or paper invoice is fine.

The 6% rate applies when all three conditions are met:

1. The home was first occupied in a calendar year at least ten years before the date of the first invoice for the works.
2. After the works, it is used exclusively or mainly as a private home (more than 50%).
3. The works are supplied and invoiced to the end consumer (the owner, tenant or usufructuary who lives there).

Cleaning is excluded. Demolition not followed by renovation, and the fees of architects and engineers, are at 21%. Materials you buy and invoice together with the works can fall under 6%; materials the client buys themselves are always at 21%.

There is no separate attestation for the client to sign any more. Since 1 July 2022, the invoice itself must show the elements that justify 6% and carry a fixed clause from the FPS Finance. If the client does not dispute it in writing within one month and a condition turns out not to be met, 21% applies and the client is liable for the VAT, interest and fines.

Demolition followed by reconstruction is a separate regime, with new rules since 1 July 2025. This briefing does not cover it; check the FPS Finance page before you quote 6% on one.

What does €10,000 of works look like on each invoice?

Invoice A: a subcontractor invoices €10,000 of works to a main contractor (reverse charge, over Peppol).

Why 21% and not 6%, even when the house is a qualifying private home? Condition 3: the 6% rate needs the works to be supplied and invoiced to the end consumer. Between a subcontractor and a main contractor, that condition is not met.

Invoice B: the same €10,000 of works invoiced directly to a private homeowner (6%, PDF or paper).

The €1,500 between the two is what the homeowner becomes liable for, plus interest and fines, if a condition was not met and they did not dispute the invoice.

Does the withholding duty change any of this?

It sits on top of the VAT and does not change the invoice. Before paying a contractor for works in the sector, a business client, including a main contractor paying a subcontractor, checks www.checkinhoudingsplicht.be and withholds part of the payment when the contractor is listed for debts.

From 30 October 2026 a third duty is added for the self-employed person's social-contribution debts: 15% of the amount excluding VAT, paid to the RSVZ. On invoice A, if the subcontractor is listed, the main contractor pays €1,500 to the RSVZ and €8,500 to the subcontractor. A homeowner renovating purely for private purposes is exempt. Thresholds, the RSZ rate and the 50% cap are in the briefing on the new withholding duty.

What should I do this month?

1. For each business client, record whether it files periodic VAT returns. A VAT number alone does not tell you.
2. Send one reverse-charge test invoice and check it: category AE, the client's VAT number, and the full "Verlegging van heffing" / "Autoliquidation" clause in the note.
3. On private renovation invoices at 6%, state the year the home was first occupied and add the fixed 6% clause.
4. If you pay subcontractors, check the withholding duty before every payment.