E-invoicing via Peppol: what legal implications should you be aware of?
December 2025 - The deadline of January 1, 2026—when e-invoicing via the Peppol network will become mandatory for all B2B transactions between VAT-registered companies—is fast approaching. Yet many entrepreneurs and their accountants still have questions about the legal implications. We summarize a few points to consider.
No automatic approval upon receipt
One of the biggest misconceptions is that an invoice that enters the accounting system via Peppol is automatically considered approved. This is not the case. Receiving or even automatically entering a Peppol invoice does not imply agreement to pay. The customer always retains the right to check and dispute the invoice, even after it has been provisionally processed.
Peppol is only a secure channel for data exchange, not a platform that regulates legal acceptance or payment. A dispute must still be handled in the usual way—by email, registered letter, or according to the company's internal procedures.
Payment remains outside the network
The obligation to use e-invoicing does not change payment methods or terms. Invoices via Peppol are still paid as agreed in the contracts or general terms and conditions—for example, by bank transfer, QR code, or payment platform. The legal or contractual payment terms also remain in force.
Reminders outside Peppol
The Peppol network is not intended for communication about payments. Anyone who wants to remind a customer about an outstanding invoice must do so via other channels, such as email or the built-in functions of accounting software. It is important to always refer to the original Peppol invoice and the agreed due date.
Paper or PDF invoices become illegal
From 2026, paper or PDF invoices will no longer meet the legal requirements between Belgian companies. If you still receive one, it is wise to refuse it with justification. State that the invoice was not sent via Peppol and is therefore not legally valid. If you also disagree with the content of the invoice, it is best to add this to the same refusal.
Review your general terms and conditions
Suppliers are advised to amend their general terms and conditions of sale. State explicitly that invoices will now be sent and received via Peppol.
It is also worth adding a fraud warning or risk mitigation clause. Peppol makes invoicing more secure, but does not completely rule out fraud. Companies remain responsible for their own checks, such as verifying supplier details and Peppol IDs.
Foreign suppliers: transition period until 2030
For the time being, the obligation only applies to invoices between Belgian VAT payers. Foreign suppliers may continue to send traditional invoices until July 1, 2030. However, it is a good idea to anticipate this now, as many countries are introducing e-invoicing more quickly. In France, for example, it will be mandatory as early as September 1, 2026.
