Beltug Vendor Observatory event raises questions on Peppol adoption

The session highlighted the importance of early planning and coordination to ensure a smooth shift to structured electronic invoicing in Belgium’s B2B landscape. Participants expressed concerns about Peppol adoption, and how the transition to eBilling on the Peppol network would affect various aspects of invoicing processes.

Beltug followed up with the Federal Public Service (FOD/SPF) Finance to seek clarity on these issues, and we have received answers:

• The future of the HERMES system: Currently, businesses using HERMES receive invoices in PDF format. Beltug members wonder whether this option will remain available after the 2026 deadline. Additionally, there is confusion around visibility—companies on HERMES may appear to be using Peppol when they are not.
  Answer Federal Public Service Finance: HERMES will remain active. In principle, this can be used as a receiving tool (although this is not our preferred approach), but it does not support the sending of invoices. In practice, most companies that are currently active on HERMES will in any case need to find another solution. As a government entity, we are also considering raising awareness among people who are still registered with HERMES after a certain timeframe.
• Consequences of late compliance: Businesses are seeking guidance on potential penalties or operational risks should they fail to meet the 2026 timeline.
  Answer Federal Public Service Finance: The Royal Decree, which must still go through several advisory steps (Council of State, etc.) before it is published, states there will be fines in this regard.
• Handling customers not (yet) on Peppol: Questions remain on how businesses should manage invoicing if their customers are not using the Peppol network.
  Answer Federal Public Service Finance: Raising customer awareness is certainly appreciated, but this should of course not be at the expense of a company’s own functioning. If a customer cannot be reached via Peppol, the supplier may send the invoice in any way they choose. This means via PDF by email or even on paper. This is certainly not the ideal situation, but the priority is that companies can continue to invoice and be paid.
• Cross-border invoicing: Our members want to understand how cross-border transactions will be handled under the new system.
  Answer Federal Public Service Finance: There is no obligation here, so you can agree with your customer on how you will invoice.
• EU-wide mandate: They are also seeking confirmation on whether eBilling will become mandatory for all EU Member States by 2030.
  Answer Federal Public Service Finance: This issue is more nuanced. In principle, the VAT in the Digital Age (VIDA) agreement only mandates this for transactions between companies in two different Member States. Internally, the Member States remain authorised to decide whether or not to implement it. In practice, we see that it is almost certain that all Member States have laws or plans in place to introduce this requirement at the national level.

38% of Beltug members (mainly large organisations) are already using Peppol. Beltug plans to look further into the issue, to analyse adoption rates across different sectors and help its members prepare for the transition.

Presentations and the replay from the ‘Beltug Vendor Observatory: focus on B2B eBilling with Peppol’ are available for Beltug members (after login) here.