| According to figures from the European Commission, the EU lost approximately €61 billion in VAT revenue in 2023, of which almost €2.5 billion in Belgium. One of the main causes of this “VAT gap” is the outdated VAT legislation. To address this problem, the European Commission has set up the VAT in the Digital Age (VAT in the Digital Age), or “ViDA”.
The aim of this project is to modernise and digitise (including real-time reporting and electronic invoicing) the current invoicing process in order to adapt it to the current digital economy and combat the loss of VAT revenue. In view of these challenges, the ViDA project has set itself three main objectives, which it intends to implement in phases by 2035: |
I. Electronic invoicing and digital reporting obligations (DRR)
This objective focuses on the Europe-wide implementation of electronic invoicing and the implementation of electronic real-time reporting/declaration systems to facilitate the automatic exchange of data between EU countries. This will promote transparency and reduce VAT fraud.
The implementation of this objective is spread out over time as follows:
From 2025:
- Member States may impose electronic invoicing obligations for national-local transactions without prior authorisation from the European Commission, provided that these measures are limited to taxable persons established in their territory (more on this below).
From 2026, specifically for Belgium: Mandatory structured electronic invoicing – in accordance with the Royal Decree published on 14 July 2025:
- Mandatory for B2B transactions
From 1 January 2026, all VAT-registered entities established in Belgium must issue and receive structured electronic invoices for their (non-exempt) B2B transactions. Permanent establishments of foreign VAT-registered entities are therefore covered, but foreign VAT-registered entities without a permanent establishment are not.
- Peppol BIS as the required format
All structured electronic invoices must be sent via the Peppol network, which complies with European standard EN 16931. However, by mutual agreement, another structured electronic format may be used if it complies with the European standard. By 2026, it must therefore be technically possible to send and receive Peppol BIS e-invoices via the Peppol network. The PDF format is no longer acceptable. The FPS Finance will publish a list of approved software that meets this requirement.
- New fines
In addition to the current fines for non-compliance with the invoicing requirements (e.g. late/incorrect invoicing), new fines will be introduced for failure to comply with the obligation to be technically capable of sending and receiving Peppol BIS e-invoices via the Peppol network. A fine of 1,500 euros will be imposed for a first offence, 3,000 euros for a second offence and 5,000 euros for a third offence.
- Presumably from 2028 (limited) digital reporting in Belgium
From 1 January 2028, Belgium will introduce near real-time e-reporting for domestic transactions to replace the annual Belgian client listing.
- Rounding rules
From 1 January 2026, rounding will only be permitted on the total amount per VAT rate and no longer at line level.
From July 2030:
- Electronic invoicing (in accordance with European standard EN 1693) will be mandatory for cross-border B2B transactions within the EU;
- Intra-Community sales listings will be replaced by a European central real-time reporting platform. Real-time reporting will become a condition for the application of the VAT exemption for intra-Community supplies, and acquirers must report the acquisition within five days;
- National e-invoicing systems (except those established before 2024) must comply with the European standard;
- Invoices must be issued more quickly, i.e. within 10 days of the chargeable event. They must also contain additional information, such as bank details.
From January 2035:
- National e-invoicing systems introduced before 2024 must also comply with the European standard.
However, it remains problematic that, at least until 2035, Member States will continue to use their own VAT reporting procedures, and each Member State will be able to develop its own DRR system, meaning that there will be no standardised EU system.
II. Fewer local VAT registrations through the expansion of the One-Stop Shop (OSS)
Although a “one-stop shop” (I)OSS already exists today, it will be expanded step by step:
From July 2028
- This could be used for all B2C sales (both goods and services) within the EU (if no local VAT registration is available);
- All intra-Community transfers of (own) goods could be reported via this new OSS;
and a mandatory domestic reverse charge mechanism should apply to B2B supplies by non-established suppliers, as we have already today in Belgium. In principle, these should not be reported via the extended OSS, but via a DRR system that is yet to be developed.
However, it remains problematic that it still will not be possible to claim VAT refunds via the extended OSS.
III. The platform economy
From January 2030 (optionally already from July 2028)
- The “deemed supplier” principle will apply in the case of short-term rentals: Digital platforms that “facilitate” passenger transport and short-term rentals will be responsible for collecting and paying VAT on behalf of suppliers who do not do so themselves.
In case you have any questions on this or would like to obtain a detailed analysis, please do not hesitate to contact our team of VAT experts, under supervision of Thomas Hermie (t.hermie@euregio.law / +32 499 24 07 81).
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