Belgium Is Not Done: Near Real-Time E-Reporting Lands in 2028

From four corners to five

Belgium's current mandate is a classic four-corner model: your provider sends the structured invoice across Peppol to your customer's provider. Nothing goes to the tax administration in the process. The 2028 proposal adds a fifth corner. Mandatory invoice data is transmitted to the FPS Finance almost immediately after the invoice is issued, with the tax authority effectively becoming a participant in the exchange network.

This is the step that turns e-invoicing into continuous transaction controls. The invoice still travels supplier to customer as it does today, but a defined set of data travels to the state in parallel, in near real time rather than in a periodic return.

• Start date: 1 January 2028
• Scope: domestic B2B between Belgian-established and VAT-registered businesses
• Bilateral: both the supplier and the customer report
• Five-corner Peppol model, near real-time transmission of mandatory invoice data
• Replaces the annual client listing for businesses in scope

Bilateral reporting is the part to read twice

Most reporting regimes put the obligation on the seller. Belgium's draft puts it on both sides: the supplier reports what it issued, the customer reports what it received. That gives the administration a matched pair for every domestic B2B transaction and makes mismatches, the classic signal of missing-trader fraud, visible almost immediately.

For businesses, it means the reporting obligation is not something you can delegate entirely to whoever sends your invoices. Your inbound invoice flow becomes a reporting flow too. If inbound structured invoices currently land in a mailbox and get keyed in by hand, that arrangement stops working in 2028.

One obligation removed

There is a genuine simplification in the package: for taxpayers in scope of the new reporting, the annual list of taxable clients, the client listing Belgian businesses have filed every March for decades, is repealed. The data it carried is already in the real-time stream, so the periodic return loses its purpose. That is the trade the government is offering: continuous data in, an annual filing out.

Why 2028 and not 2030

The EU's VAT in the Digital Age directive makes digital reporting for intra-EU B2B transactions obligatory from 1 July 2030. Belgium is deliberately running ahead of it on domestic transactions, in the same way it ran ahead on e-invoicing. The logic is the same both times: build the domestic system first, then plug it into the EU-level requirement rather than doing both at once under a hard deadline.

Businesses that treated the 2026 mandate as a one-off project rather than as a capability will feel this. Businesses whose invoices already move as structured data over a network are, for the most part, already holding the raw material the 2028 rules ask for.

What is still to be settled

The draft is preliminary. It is under review by the Data Protection Authority and the Council of State, and has not yet been submitted to Parliament, so the exact data set to be reported, the timing tolerance behind the phrase near real time, the treatment of non-established but VAT-registered businesses, and the penalty regime can all still move. What is unlikely to move is the direction and the date, which line up with both the government's stated fraud-reduction goals and the ViDA timetable behind them.

What to do with the next fifteen months

The practical preparation is unglamorous and starts with inbound. Make sure structured invoices you receive are captured as data rather than printed, viewed or retyped, because in 2028 you have to report them. Keep the original XML as the invoice of record. Check that your master data, VAT numbers and Peppol identifiers on both your customer and supplier records, is accurate, because matched reporting is only as good as the identifiers it matches on.

On the network side, most of the groundwork is shared with the 2026 mandate. Five-corner reporting reuses the same Peppol infrastructure, with the tax administration added as a participant, so this is an extension of an existing connection rather than a second integration. What does not exist yet is the detail: OpenPeppol and the Belgian authorities still have to publish the reporting document type, the process identifier and the FPS Finance endpoint specifications before any provider can implement against them. Until those land, ask your provider where five-corner reporting sits on their roadmap, and treat a confident claim of support today with mild suspicion. Nobody can be finished with a specification that has not been written.

At Invoro, our access point already runs the pieces the 2028 model builds on, including Peppol exchange, message level status and real-time reporting integrations for other national regimes such as Hungary's NAV and Poland's KSeF. Belgian five-corner reporting is on our roadmap and we are tracking the draft law and the technical specifications as they develop.