Regulatory updates - Belgium

Belgian SAF-T is based on the OECD SAF-T 2.0 xml structure. The draft schema reportedly has 300 to 400 data fields, so businesses that want to use it will need to map their ERP data to the Belgian structure. Businesses whose ERP or accounting systems support the format may upload requested data through MyMinfin. Those that cannot produce Belgian SAF-T may still provide the data in another readable format.

Note that Belgian SAF-T is not a periodic VAT return or a transaction reporting requirement. It is only used when the authorities request data during an audit and is separate from Belgium's near real time e-reporting planned from January 2028.

On July 18, the Council of Ministers approved a pre-draft law introducing dual e-reporting from 2028. The reform builds on the e-invoicing obligation for domestic B2B transactions already in force since January 1, 2026, adding a requirement for mandatory invoice data to be transmitted to tax administration in near real time.

This reporting duty is designed as a dual obligation, with the supplier reporting the sale side and the customer the purchase side of the transaction. The government presents this bilateral approach as a way to improve compliance through more digitized and reliable data flows, while also giving tax authorities faster, more detailed information that strengthens risk-based controls.

As a counterbalance to this new obligation, the draft law abolishes the annual customer listing for businesses subject to the new e-reporting duty, offering a measure of administrative simplification alongside the added reporting requirement.

The pre-draft law has now been submitted for review to the Data Protection Authority and the Council of State before it can progress further through the legislative process.

FPS BOSA has announced that the Belgian Peppol Authority will be transferred to FPS Finance as of 2027. The Belgian Peppol Authority was originally established by FPS BOSA at the end of 2015 and has since played a central role in the Belgian e-invoicing landscape.

The transition is driven by the introduction of e-reporting, which requires specific tax expertise that falls more naturally within FPS Finance's remit. The move aims to ensure greater consistency, clearer responsibilities, and more effective decision making as Belgium's e-invoicing and e-reporting framework continues to evolve. FPS BOSA and FPS Finance are already working together to ensure the transfer is structured, legally compliant, and operationally stable.

At this stage, no action is required. Further details on the practical arrangements and timeline will be shared in due course through the usual communication channels, including the Peppol Service Provider Forum, Business Expert Group meetings, and the websites of both FPS BOSA and FPS Finance.