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. Since March 2024, all public procurement contracts for a total amount of minimum 3K€ must include the mention that the related invoices must be sent to the public institution through Peppol.

B2B invoicing through Peppol will become mandatory for all companies on 01/01/2026 (see decision on 29/09/2023 and the decree approved on 01/02/2024 in the Parliament. This concerns all Belgian VAT registered companies for all their invoices and credit notes sent to other Belgian VAT registered companies (see the details of the B2B obligation. Belgium has decided to take a staged approach. The next steps will probably be e-reporting (scheduled in the governemental agreement for 2028) and then the CTC as mandated by the European Commission.

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. The last step of the obligation for the small companies had 18/03/2023 as deadline.

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. This integration is however performed in a way that does not respect the Peppol approach. The French administrations are not present in the Peppol registry and they are only addressed through the Chorus Pro endpoint acting as a black-box.

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:

In Digiteal, we believe that the French specific system is too ambitious and not standard enough to succeed. We are not registered as a PDP candidate as

Of course, the companies can choose to start receiving and sending electronic invoices sooner if they want. They can also be directly connected through Peppol for maximum interoperability.

EU Countries

An overview of the e-invoicing obligations in all the EU countries is provided in the e-invoicing documentation of the European Commission.

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 initiative is called ViDA (VAT in the Digital Age).

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. All countries of the EU must support interoperable cross-border e-reporting by 2030 (except Italy that has until 2035 to comply because they already had a running clearing system before ViDA was decided upon). This will lead to a much wider adoption of Peppol as the perfect solution to support this interoperability and the Decentralized Continutous Tax Control (D-CTC) enabling e-reporting for the whole European Union.