Electronic Invoicing in the Benelux Region: Latest Updates for Belgium, the Netherlands, and Luxembourg

Benelux made up of Belgium, Netherlands, and Luxembourg continues its electronic invoice adoption process. While it is already extensively implemented in public administration contracts regulated by European laws, the pace of progress varies when it comes to business-to-business transactions.

The electronic invoice in Belgium advances at various speeds

B2G Invoicing in Belgium

Electronic invoicing is mandatory for all suppliers of public institutions in the B2G (Business-to-Government) sector. The implementation of this requirement has been done progressively, based on the scale of the public contracts involved.

Regarding B2G e-Invoicing, there is an obligation to issue electronic invoices to all suppliers of public institutions in the country. The obligation was adopted gradually, and according to the size of public contracts. 

The Federal Government’s platform is called Mercurius, and it is connected to the Peppol network in the PEPPOL BIS 3.0 format. All government organisms have access to the Mercurius platform to receive invoices. Public administrations can also connect through their own  Peppol ID or another connection method.

The digital signature is not mandatory and invoices must be archived for 7 years.

B2B Invoicing in Belgium

The Belgian Ministry of Finance has announced its plan to gradually enforce mandatory B2B electronic invoicing starting in July 2024.

Currently, the ministry has proposed a three-phase gradual implementation of B2B electronic invoicing, which is still pending confirmation:

• In July 2024, taxpayers established in Belgium with an annual turnover, excluding VAT, exceeding 9,000,000 euros during the calendar year 2023 will be included.
• By January 2025, taxpayers established in Belgium will be subject to the requirement if their annual turnover, excluding VAT, surpasses 700,000 euros during the calendar year 2023, but does not exceed 9,000,000 euros, or if it exceeds 700,000 euros, excluding VAT, during the calendar year 2024.

The inclusion of small taxpayers with a turnover below 700,000 euros is expected in July 2025, but this is subject to confirmation.

The Netherlands, no further e-invoicing developments 

The Netherlands made it mandatory to electronically invoice public administrations in 2017.

Currently, central public administrations and consolidating authorities are both mandated to be able to receive and process electronic invoices. Suppliers with contracts dating after 2021 must issue electronic invoices, those with contracts from before can voluntarily comply.

The central public administrations are connected to the Digipoort central platform that is connected to the PEPPOL network. Currently, electronic invoices can be sent in Peppol BIS 3.0 format. EDICOM is certified as an authorized supplier of Peppol services for electronic invoicing in the Netherlands by the Dutch Peppol authority Nederlandse Peppolautoriteit (NPA). Any company can use EDICOM’s platform to send and receive invoices through the Peppol network.

Like the public administrations in Belgium the local public administrations tend to connect through their own Peppol ID.

Since January 2021 the Peppol authority (Nederlandse Peppol Autoriteit) belonging to the ministry of internal affairs has stated that the digital signature is not mandatory and that invoices must be stored for 7 years.

Private companies can user electronic invoices as long as their clients accept the invoice and it meets the legal requirements.

Luxembourg, mandatory B2G electronic invoicing

All companies in the country are required to issue B2G (Business-to-Government) invoices to public institutions. The widespread implementation was finalized in March 2023.

Electronic invoices must be sent through the Peppol network using the PEPPOL-BIS 3.0 standard.

The development of the electronic invoicing model is under the Ministry of Digitalization and Government IT Center (Centre des technologies de l’information de l’Etat - CTIE). The government intends to make the issuance of electronic invoices manually through a website and a web form that will facilitate its use for companies with a low invoice volume.

Regarding digital reporting compliance, the Luxembourg tax authority can demand that companies send the FAIA electronic file with a company’s accounting information in case of an audit.

Global Electronic Invoicing Platform

Electronic invoicing provides an advantage to any company that looks to compete for public contracts. Therefore, working with an International electronic invoicing solution opens the door to the Benelux countries: Netherlands, Luxembourg, and Belgium.

EDICOM’s electronic invoicing platform has connections with more than 70 public administrations around the world.

Amongst the many services it offers it guarantees a connection to the PEPPOL network as a certified Peppol Access Point. Making it the perfect solution to transact with public administrations in Benelux. EDICOM’s solution also enables any other kind of connection (AS2, Webservices, SFTP…) that other local public administrations may choose as is allowed in Belgium.

On the other hand, EDICOM guarantees the continuous evolution of the platform to new legal and technical requirements imposed by governments and tax authorities. This is an essential service since national electronic invoicing systems are in a state of constant evolution.

EDICOM coordinates GOVEIN2019 project (Action No: 2019-EU-IA-0046)

*The contents of this publication belong solely to EDICOM GROUP and do not necessarily reflect the opinion of the European Union.