Belgium's 2026 Peppol B2B e-invoicing mandate: what transport companies need

Since 1 January 2026, a PDF attached to an email is no longer an invoice between two Belgian companies. If you run trucks out of Belgium and bill Belgian shippers, your invoicing changed that day, and so did the way Belgian subcontractors bill you. What follows is the rule as FPS Finance, the Belgian tax administration, presents it on its e-invoice portal.

Structured electronic invoicing is compulsory for B2B transactions between Belgian VAT-liable companies, for invoices drawn up, issued or sent from 1 January 2026. In practice the route is Peppol: software connected to the Peppol network that sends and receives structured invoices. The administration cites article 53, §2bis of the VAT Code as the legal basis. Invoices to consumers are excluded.

Sending and receiving, for every VAT-liable company

According to the FPS Finance e-invoice portal, the obligation covers all Belgian enterprises liable to VAT, including those under the small-business exemption. A VAT-registered person who is not established in Belgium and has no permanent establishment there is not subject to it, although the FAQ added that the law was still being amended on that point when we read it.

The obligation runs both ways, and the second direction is easy to miss. You must be able to issue a structured invoice to your Belgian business customers, and you must be able to receive them from your suppliers: subcontracted carriers, fuel suppliers, tyre dealers and workshops. Joining Peppol counts as agreeing to receive structured e-invoices.

What no longer works

Sending a PDF by email or through a platform is no longer enough, the portal says. Three points in the FAQ land straight in a transport back office:

• A recipient cannot reject an invoice because no PDF is attached. The structured data carries the invoice.
• Attachments such as a signed CMR or a proof of delivery must travel through the same channel as the invoice, and sending them separately by email is not allowed. The standard accepts pdf, png, jpg, csv, xlsx and ods attachments, and a UBL invoice can carry them directly.
• If a supplier is not ready, the customer keeps the right to deduct VAT on an invoice issued in another form, provided both parties agreed on a secure alternative.

What a transport invoice should carry

A transport invoice on Peppol is the same invoice in a structured format, and a few fields decide whether the other side can process it without calling you. Many payables teams match first on the buyer reference and purchase order number, so use the customer's own order reference. The buyer address must be complete (street, city, postcode and country), and a missing street gets the invoice refused. Belgian customers expect the structured communication ("OGM") next to the IBAN. State the document currency explicitly. One invoice per order or a consolidated invoice both travel on Peppol, as long as each line traces back to its order.

Those are the fields Druma checks and fills. It checks the buyer's address before sending and carries the buyer reference, the purchase order reference, the currency and the structured payment reference on each invoice. Druma sends through a Peppol provider, Recommand, and is not an Access Point itself: you register your Belgian company number once in Settings, invoices to Belgian clients route over Peppol, and delivery status comes back as sent, delivered or failed. Credit notes and consolidated invoices go the same way, and if Peppol fails or the buyer is not on the network, the invoice goes out by email. Receiving is the gap. Druma does not take in Peppol invoices, so supplier invoices need your accounting package or a Peppol-connected inbox. As of October 2026 the flow has been tested end to end in Recommand's sandbox; the Peppol feature page lists what each invoice carries.

Setting up as a haulier

Start with a Peppol connection through an Access Point provider; your Belgian company number is the identifier. Then ask each Belgian customer for their Peppol ID and check it in the public directory. Decide who handles supplier invoices and how they arrive. Fill in order references and the structured payment communication on every order, because the invoice is built from them. Keep an email fallback for customers who are not on the network yet.

Penalties and the tolerance period

FPS Finance announced that it would not penalise offences against the new obligation during the first three months of 2026, as long as the company showed it had acted in a timely and reasonable manner. That window has closed, and each case is judged on its own facts. For self-billing the administration announced flexibility until 30 June 2026.

On amounts, Belgian advisers report that a royal decree of July 2025 introduced administrative fines for companies without the technical means to send or receive structured invoices: €1,500 for a first infringement, €3,000 for a second and €5,000 for later ones, with at least three months between them. The FAQ pages we read do not list these figures, so check the royal decree itself before you quote them to anyone.

Foreign customers and foreign carriers

The Belgian rule is about transactions between Belgian VAT-liable companies, and the portal says using Peppol with foreign partners is voluntary for now: both sides must choose it.

An Eastern European haulier that bills a Belgian shipper without a Belgian establishment is not subject to the obligation, says the FAQ. The Belgian customer may still ask for Peppol, because its own payables process now expects it. You can agree for commercial reasons, but the law does not require it. The portal also looks further ahead: from 2030 the obligation will extend to invoicing between EU Member States, with the details still to come.