Belgium’s 2028 E-Reporting: What It Means for Your ERP

Most Belgian companies spent 2025 getting ready for Peppol, and most got there. Since January 1, 2026, structured B2B e-invoices flow between businesses, the tolerance period ended on March 31, and the fines for not being able to send and receive them (€1,500 for a first infringement, rising to €3,000 and then €5,000) now apply. For a lot of finance teams the project is closed and the access point is simply another supplier.

Belgium e-reporting from 2028 is the next step, and it is a different kind of project. On July 18, 2026 the Council of Ministers approved a pre-draft law that, from January 1, 2028, would have the tax authority receive invoice data in near real time as part of the Peppol exchange. Both the supplier and the customer would report. That second detail is the one that should change how you plan 2027, because it means the authority will be able to compare your version of an invoice with your counterparty’s version, invoice by invoice.

What the Belgian e-reporting draft for 2028 says, and what it does not

According to the summaries published by KPMG and EY in July, the pre-draft law would do the following.

• Introduce near real-time e-reporting of invoice data for domestic B2B transactions from January 1, 2028.
• Apply to both sides of the transaction: the supplier reports the sales invoice, the customer reports the purchase invoice.
• Build on the existing Peppol network in a so-called five-corner model, in which the tax authority becomes a participant in the exchange rather than an outsider receiving returns.
• Abolish the annual client listing for businesses that fall under the new regime.

What is not known yet matters just as much. The exact reporting window, the full data set, how corrections and credit notes are handled, and the penalty regime are not settled in the public summaries. The draft has gone to the Data Protection Authority and the Council of State for their opinion; publication of the law and an implementing Royal Decree are expected to follow. Plan for the direction, which is clear, and leave room for details that will move.

Why this is a data project, not a connectivity project

Peppol forced a technical question: can your ERP produce and receive a structured invoice in the right format, through an access point? The answer was mostly a connector, a mapping and some testing. E-reporting asks a harder question: is the data in that invoice right, and does it match what your customer or supplier recorded?

Today, when your purchase ledger books an invoice with a different VAT code than your supplier used, nobody notices unless there is an audit. When a credit note is booked in the wrong period, it evens out in the annual listing. Under a dual reporting model, both versions reach the authority within a short time of each other. Every mismatch becomes visible as it happens, not years later. The companies that will struggle in 2028 are not the ones without an access point; everyone has one now. They are the ones whose master data and booking practices were built for a world in which nobody was comparing.

Where mismatches come from in a typical mid-market ERP

In the ERP environments we work in, the same few sources produce most of the inconsistencies. None of them are new. E-reporting simply makes them expensive.

• Customer and supplier master data: wrong or missing enterprise numbers, duplicates of the same company, VAT numbers that were never validated.
• VAT codes chosen by hand at booking time, especially for mixed or partially exempt purchases.
• Purchase invoices entered manually from a PDF when the structured version was available, with the booking date, amounts or VAT split typed differently.
• Credit notes and corrections that are booked as negative invoices, split across periods, or not linked to the original.
• Intercompany invoices between Belgian entities of the same group that each side books its own way.
• Invoices received through Peppol but still processed as if they were PDFs, so the structured data never reaches the ledger.

The last one is worth a moment. Many companies became Peppol-compliant by adding an access point that turns incoming invoices back into a document for someone to key in. That satisfied the 2026 obligation. It will not help in 2028, because the value of e-reporting for the authority is that the data is structured end to end.

A 2027 work plan for finance and IT

You have roughly five quarters before January 2028. That is enough time if the work starts in the first half of 2027, and not much if it waits for the Royal Decree. A reasonable sequence looks like this.

1. Q4 2026: ask your ERP vendor or partner and your Peppol access point provider, in writing, how they plan to support e-reporting and when. Put the answers in your 2027 budget.
2. Q1 2027: clean customer and supplier master data. Validate every Belgian enterprise and VAT number, merge duplicates and decide who owns master data changes from now on.
3. Q1 to Q2 2027: review how VAT codes are determined. Replace manual choices with rules where you can, and document the exceptions.
4. Q2 2027: route structured incoming invoices directly into the purchase ledger. Measure how many are still keyed in by hand, and why.
5. Q2 to Q3 2027: fix credit notes and corrections, so every correction references the invoice it corrects and lands in the right period.
6. Q3 2027: reconcile a sample of your largest suppliers and customers against their records. The mismatches you find are the ones the authority will find.
7. Q4 2027: test the reporting flow end to end with your access point, and agree who in finance handles rejected or mismatched reports each day.

Who should own it

The mistake many companies made with Peppol was to treat it as an IT project. It went well technically and changed nothing in finance. E-reporting has to be owned by finance, with IT and the ERP partner in support, because the decisions are about VAT treatment, booking rules and master data governance. If you have an application manager for the ERP, they are the natural bridge between the two. If you do not, this is a good reason to have one for 2027. We describe the role in The ERP Application Management Guide.

For groups with entities in other countries, the Belgian project will not be the last. The Netherlands, Germany and France are all on their own timelines towards the EU’s VAT in the Digital Age rules, which bring digital reporting for intra-EU transactions from July 2030. The master data and booking discipline you build for Belgium is the same foundation those will need.

The bottom line

Belgium’s e-reporting plan is still a draft, but its direction is clear: from 2028, both sides of every domestic B2B invoice are expected to be visible to the tax authority in near real time. The work that decides whether that goes smoothly is not technical. It is clean master data, rule-based VAT codes, structured purchase processing and properly linked corrections. All of that can be done in 2027 at a sensible pace, or in the last quarter under pressure.

The ERP Application Management Guide

Process Mapping 101: A Practical Guide

Application management services

Sources

KPMG TaxNewsFlash: Belgium proposal to introduce e-reporting of invoicing data from 2028

EY Tax News: Belgium announces proposed e-reporting requirements beginning in 2028

Loyens & Loeff: e-invoicing in Belgium from January 1, 2026, key provisions of the Royal Decree

European Commission: VAT in the Digital Age