Mandatory e-invoicing

Belgium

In Belgium, B2G e-invoicing is mandatory in Flanders since 2020. This has been extended to the whole country in 2022 and is enforced through the call for tenders issued by the public authorities with the following timeline:

Belgian public contract total amountB2G mandatory starting on
>215K€November 2022
>30K€May 2023
>3K€March 2024

B2B invoicing through Peppol will become mandatory for all companies on 01/01/2026 (see decision on 29/09/2023. The decree making this official has not been finalized yet but it will be confirmed soon by the Council of State and the Parliament. Belgium has decided to take a staged approach. The next steps will probably be the CTC as mandated by the European Commission.

Belgian company sizeB2B mandatory starting on
All01/01/2026

Luxembourg

In Luxembourg, B2G e-invoicing through Peppol is mandatory as stated in the law of 13/12/2021. This obligation has been enforced gradually to all companies:

Luxemburg company sizeB2G mandatory starting on
Large18/05/2022
Medium18/10/2022
Small18/03/2023

There is no obligation yet for B2B eInvoicing but it is however encouraged.

France

In France, B2G e-invoicing is already applicable in France through the Chorus Pro portal. UBL, FactureX and CENBII can be used as exchange format. Chorus Pro provides the necessary gateway to interface the French System with Peppol. B2B e-invoicing was made mandatory in the article 26 of the finance law revision of 2022. However, the initial timing of the obligations was too ambitious and the obligations have been delayed on 28/07/2023. The current calendar for the application of these obligations is:

CapabilityMandatory starting on
Receive electronic invoices01/09/2026
Send electronic invoices (large companies)01/09/2026
Send electronic invoices (SMEs)01/09/2027

Of course, the companies can choose to start receiving and sending electronic invoices sooner if they want.

EU Countries

In an EU Commission update, the EC pushes to set up a standard for reporting and mandate obligatory eInvoicing to improve VAT collection and transparency in the EU. They call this the Digital Reporting Requirements which is a type of federated Continuous Tax Control (CTC) for the EU Digital Single Market.

This involves all the EU countries (not only the ones that use PEPPOL today) and leads to a higher requirement for interoperability. For example, France must also comply with this through more interoperability with Peppol as described in this update of the French DCTCE.