Belgium plans to make every VAT-registered business report its invoice data to the tax authority electronically, close to real time, from 1 January 2028. The data comes from the structured e-invoices you already exchange over Peppol since 2026, and both sides report: the supplier who issues the invoice and the customer who receives it. For those businesses, the annual client listing disappears. It is a bill, not yet a law: the government filed it in the Chamber on 27 October 2026, and the deadlines and the exact data are left to a royal decree that has not been published.

If your invoices already go through Peppol, the bill's own impact analysis expects that "practically nothing will change" for you: your software adds a function that forwards the data. The work sits with software providers. Your part is to make sure everything you invoice really goes through that software, and to know what happens to an invoice the moment it arrives.

What the bill says

The bill is DOC 56 1846/001, "amending the VAT Code as regards the introduction of the electronic reporting obligation and the abolition of the obligation to file the annual list of taxable customers". The Council of Ministers had approved a draft on 18 July 2026, as EY reported at the time. The main points of the text filed in October:

Point	What the bill says
Start	Article 3: the law takes effect on 1 January 2028.
Who reports	In principle both parties: the supplier who issues a structured e-invoice, and the customer who receives it. The explanatory memorandum calls it two-sided reporting.
What is reported	The data that must already appear on the structured e-invoice, as designated by the King. Per invoice, not totals per period.
When	Set by royal decree, at most five calendar days, except in cases of force majeure the decree defines.
How	Over the Peppol network. The FPS Finance will not build a separate application or API.
Corrections	A credit note or other correcting document is reported like the invoice it corrects.
Client listing	Abolished for businesses subject to e-reporting.

The data goes out before you have had time to check the invoice. The memorandum says so plainly: because reporting happens so soon after the invoice is issued or received, it will often come before the parties can check whether the invoice is correct ("business validation"). What is reported is the invoice as it was sent and received. If it turns out to be wrong, the correction is reported too.

What replaces the annual client listing

Today you file a list of your Belgian VAT-registered customers once a year, with the totals you invoiced each of them. Under the bill, that list is replaced for businesses that report electronically, because the tax authority will already have every invoice, line by line, within days.

Two details matter for the transition:

Transactions carried out in 2027 still go on a client listing in the old way, filed in 2028. The new rules apply to transactions from 1 January 2028.
Businesses not established in Belgium but VAT-identified here keep filing a client listing for their transactions from 1 January 2028 to 30 June 2030, unless they choose to report electronically for all of them.

How this fits with Peppol and the EU rules

Since 1 January 2026, Belgian VAT-registered businesses have had to exchange structured electronic invoices with each other, and Peppol is the network that carries them. E-reporting builds on that: the invoice that travels from your provider to your customer's provider is the same document whose data is reported.

The EU's VAT in the Digital Age package, Council Directive (EU) 2025/516, introduces digital reporting for transactions between member states from 1 July 2030, and lets member states set up their own reporting for domestic transactions. Belgium is doing the domestic part first. The bill's maximum of five calendar days mirrors the longest deadline in the directive, so that the Belgian system needs as little change as possible when the EU rules apply in 2030.

What we don't know yet

The vote. The bill can still change in Parliament.
The royal decree. It will set the exact deadlines (at most five calendar days), the list of data fields and the Peppol address the data goes to.
Fines. The bill text does not set amounts for e-reporting; don't trust a figure you read elsewhere until it is published.
Edge cases. The bill has specific rules for VAT units, the flat-rate scheme for farmers and foreign businesses. If one of those is you, ask your accountant.

What to do now

Most of this lands on your software provider. Still, there are things only you can check.

Make sure everything you invoice goes through Peppol

E-reporting is built on the Peppol e-invoice, which is required for invoices to other Belgian VAT-registered businesses. Invoices to consumers are not part of it. List every place your business invoices other companies: the accounting package, but also a webshop with business customers, a booking system, a custom app, an export from a spreadsheet, a colleague who still sends a PDF. Anything that sends a business customer something other than a Peppol e-invoice is already a problem under the 2026 rules, and it will be a reporting gap in 2028.

Ask your provider four questions

Will you report outgoing invoices to the FPS Finance automatically from 1 January 2028?
Will you also report the invoices we receive?
Do credit notes and corrections go through the same flow?
What does it cost, and is it included in our current plan?

Process incoming invoices quickly

Because the customer reports too, an incoming invoice will be on record with the tax authority within days, whether or not you agree with it. That does not make you owe it: a wrong invoice is still corrected with a credit note, as now. But a supplier's mistake that used to sit in your inbox until the end of the quarter will be visible much sooner. Check invoices when they arrive, and ask for a credit note straight away when something is wrong. If you don't recognise the sender at all, check them before you pay.

Keep your own system in mind

If you built your own ordering or invoicing system, or a webshop that creates invoices, it has to hand them to a Peppol access point. That integration is the part a provider won't do for you. Plan it in 2027, not in December.

Checklist

Every channel that invoices Belgian businesses produces a Peppol e-invoice (accounting package, webshop, app, manual invoices).
Your provider has confirmed it will report both sent and received invoices from 1 January 2028.
You know who checks incoming invoices, and how fast.
Your 2027 client listing is planned for early 2028, the old way.
Someone is watching for the vote and the royal decree.

Why we're writing about this

We built and run Dokus, a finance tool for Belgian small businesses with Peppol e-invoicing built in, and we build web apps and webshops that issue invoices. Most businesses will not notice e-reporting, because their software will handle it. The ones that will are those with an invoicing channel that never made it onto Peppol. If you're not sure which group you're in, tell us how you invoice and we'll go through it with you.