If you issue B2B invoices in Belgium as a PEB/EPC assessor or property inspector, your invoices will have to be structured e-invoices sent through PEPPOL from 1 January 2026. PDFs by email won’t be legally sufficient in B2B anymore. Your invoicing stack therefore needs EN 16931/PEPPOL BIS 3.0 support and a PEPPOL access point connection. The rest of this article explains the what, who, when—and how to be compliant with minimal friction.

I. What PEPPOL actually is (and what it is not)

PEPPOL is a governance and technical framework used across Europe (and beyond) to exchange structured business documents, chiefly invoices, between sellers and buyers via a federated grid of certified “access points.” The content of a PEPPOL e-invoice follows PEPPOL BIS Billing 3.0, a Core Invoice Usage Specification (CIUS) that implements the EU e-invoicing standard EN16931 in a strict, machine-readable XML format (UBL 2.1).

EN16931 itself stems from Directive 2014/55/EU on electronic invoicing in public procurement, which required a common EU semantic model for e-invoices so they can be routed and processed automatically. The European Commission’s e-invoicing portal provides the legal and technical overview of EN 16931 and its documentation suite.

In Belgium, FPS BOSA acts as the national PEPPOL Authority, coordinating the ecosystem and providing government guidance on concepts like PEPPOL IDs and access points. The official FAQ also confirms the decommissioning of Hermes, the government fallback relay, on 31 December 2025, meaning you must be on PEPPOL (or via a provider) by the time the B2B mandate starts.

Bottom line: PEPPOL is not “just a portal.” It’s a network and a rulebook. Your invoice is a structured XML file (EN16931/PEPPOL BIS), delivered via a certified access point to your buyer’s access point.

II. Who is affected in Belgium (yes, that includes freelance certifiers)

From 1 January 2026, all Belgian VAT-registered businesses established in Belgium must send and receive structured B2B e-invoices, PDF alone won’t cut it. Authoritative Belgian tax commentary (Grant Thornton) puts it plainly: the structured e-invoice is the only legally compliant version from that date (you may still attach a PDF copy, but legal validity lies with the structured file).

This obligation squarely covers PEB/EPC certifiers and property inspectors/certifiers who invoice other businesses such as estate agencies, property managers, construction firms, notaries, or developer clients. Vendor-neutral overviews also confirm: the Belgian model requires PEPPOL routing using PEPPOL BIS for B2B from 2026.

There is one nuance: non-resident VAT-registered businesses without a Belgian fixed establishment are excluded from the 2026 mandate (as suppliers or customers), per a 19 March 2025 clarification summarized by VAT policy trackers. If you are established in Belgium, however, you are in scope.

B2C invoicing is not included in the 2026 Belgian obligation: private individuals can still receive PDFs, this is repeatedly noted in practitioner FAQs while B2B is mandatory structured e-invoicing.

III. The deadlines that matter (and why they matter)

Already in force (B2G): Belgium implemented Directive 2014/55/EU; public administrations must be able to receive EN 16931 e-invoices, with regional roll-outs over recent years (Flanders 2017, Brussels 2020, Wallonia 2022). This is the foundation that made B2B feasible.

• 31 December 2025: Hermes ends. No more transitional relay for parties not on PEPPOL. If you rely on Hermes today, you must migrate to a PEPPOL access point before the new year.

• 1 January 2026: Domestic B2B e-invoicing becomes mandatory for Belgian-established, VAT-registered businesses. Structured e-invoices (EN 16931/Peppol BIS 3.0) exchanged via PEPPOL are the only legally compliant form; PDFs may be sent in parallel but have no legal status.

• 1 January 2028: Belgium plans near real-time e-reporting (tax data reporting) as a second step after einvoicing; this is separate from, but complements, PEPPOL exchange.

• 1 July 2030 (EU): Under VAT in the Digital Age (ViDA), intra-EU cross-border B2B e-invoices and digital reporting become mandatory; the Commission confirms adoption on 11 March 2025 and phased implementation thereafter. For a Belgian certifier focused on domestic work, 2030 is the cross-border horizon to watch—another reason to adopt a standards-based tool now.

IV. “PDF is not the invoice anymore” (for B2B): what changes in your day-to-day

From 2026, a legally valid B2B invoice is not the PDF you email; it is the structured XML that passes validation against EN 16931/PEPPOL BIS 3.0 and is delivered over PEPPOL to your customer. The PDF may remain for human-readable convenience, but it is secondary. Belgian tax advisers emphasize this shift, including the need to respect formal VAT content requirements within the structured invoice (supplier ID, VAT numbers, taxable base, rate, etc.).

To operate on PEPPOL, you (or your software) must connect through a certified access point, and you will be discoverable via a PEPPOL ID (think “invoice address”), as the government FAQ explains. Many accounting and invoicing tools embed this access point so you don’t need to contract it separately.

On the format side, PEPPOL BIS 3.0 lays out the rules, code lists, and mapping from the EN 16931 semantic model to UBL. Sticking to BIS 3.0 is what ensures interoperability, your file will validate in your client’s system, across regions, and over time.

V. Why this matters specifically for PEB/EPC and property inspectors/certifiers

Your client base is largely business: agencies, syndics, developers, facility managers, solicitors/notaries, and construction trades. That means B2B most of the time and in 2026 those clients will expect PEPPOL invoices; many will refuse or delay payment processing without them. Sector-agnostic briefs underline that the Belgian model requires sending and receiving structured invoices and that paper/PDF is not allowed for B2B from 2026.

Beyond compliance, process quality matters. Integrated, PEPPOL-native invoicing reduces manual keying, improves cash collection, and dovetails with your broader workflow (CRM, scheduling, certificate delivery). This is not merely regulatory: a better freelance invoicing setup improves margins in a volume-driven niche.

Looking ahead, the ViDA programme means cross-border flows will also require structured e-invoicing and digital reporting by 2030; several Commission pages and practitioner summaries confirm the adoption and phased roll-out. If you sometimes certify for cross-border owners or networks, choosing tools that already align with EN16931/PEPPOL will spare you a second migration later.

VI. The compliance checklist (what to implement before new year’s day 2026)

✓ Choose an invoicing tool with native EN 16931/PEPPOL BIS 3.0

Verify the vendor’s validation against EN 16931 and conformance with PEPPOL BIS 3.0. The canonical BIS 3.0 documentation spells out the model, syntax bindings (UBL invoice & credit note), business rules, and code lists you must meet.

✓ Confirm access to a certified PEPPOL access point

You don’t onboard to PEPPOL yourself; your software’s provider typically functions as, or partners with, an access point. Belgium’s FAQ explains PEPPOL IDs, discovery, and the role of providers, and it explicitly warns that Hermes ends on 31 December 2025, so build the connection now.

✓ Clean your customer master data

You’ll need correct VAT numbers, legal names, and addresses; the slightest mismatch causes validation or posting failures. (This is where PEPPOL shines: structural validation eliminates a lot of reconciliation ping-pong.)

✓ Adapt your invoice content to Belgian formalities

The structured file must include all mandatory VAT fields. Belgian tax commentary outlines these formal requirements and clarifies that the structured e-invoice is the legally valid document for B2B from 2026.

✓ Map your incoming flow

The mandate is send and receive. Ensure your tool can receive EN 16931 invoices via PEPPOL and book them, useful when you subcontract blower door tests, rent equipment, or buy services.

✓ Plan for 2028 e-reporting and 2030 cross-border rules

Choose a provider with a credible roadmap for near real-time e-reporting (2028) in Belgium and EU cross-border DRR (2030) under ViDA. EU and vendor summaries outline those milestones clearly.

VII.Frequently asked questions from certifiers

1. Do I need PEPPOL if most of my clients are private individuals (B2C)?

No, B2C is not part of the 2026 obligation. But the moment you invoice a business (agency, developer, syndic), the B2B rule applies. Vendor and government summaries highlight that the 2026 mandate targets domestic B2B

2. I’m a foreign certifier, VAT-registered in Belgium but without a fixed establishment. Am I in scope?

As clarified in March 2025 summaries, non-resident VAT-registered businesses without a Belgian fixed establishment are excluded from the domestic B2B obligation in 2026. Check your facts, we’re talking about no fixed establishment.

3. What happens if I keep sending PDFs to business clients?

They can ask you to resend a structured EN 16931 invoice, and without it, posting and payment may be delayed or refused. Belgian tax advisories are clear that the structured e-invoice is the only legally compliant invoice in B2B from 2026.

4. What about Hermes?

Hermes (the temporary relay that converted PDFs/other formats) ends 31 December 2025. After that, use PEPPOL through an access point, often embedded in your invoicing software.

5. Is there any point doing this early?

Yes. Early movers avoid a year-end rush, fix master-data issues, and start enjoying automation benefits (fewer errors, faster cash, automatic status). Also, the 2028 e-reporting and 2030 cross-border changes mean structured invoicing is the path of least resistance long-term.

VIII.The business case (not just compliance)

A PEPPOL-integrated tool improves cash collection (fewer rejections, faster posting), reduces admin (no re-keying), and provides audit-ready documentation.

For a typical freelance practice dealing with numerous small B2B jobs like PEB, EPC, property inspectors, property certifiers, those gains compound. Vendor-neutral briefings on Belgium note that from 2026, businesses must send and receive structured invoices through PEPPOL in PEPPOL BIS format, and that paper/PDF will not be allowed for B2B; selecting a freelance invoicing tool with built-in PEPPOL greatly reduces friction.

Even if you presently juggle quotes, POs, and invoice status by email and spreadsheet, switching now means you won’t be scrambling in December to meet mandatory connectivity and format rules.

IX. How to brief your accountant and your clients

• Tell your accountant which solution you’re adopting and confirm that incoming e-invoices will land in their system via PEPPOL.

• Notify repeat B2B clients that from 1 January 2026 you’ll be issuing via PEPPOL and ask for any PEPPOL ID or internal routing reference they prefer.

• Update your terms to reflect structured e-invoicing, including how credit notes will be issued (PEPPOL BIS includes credit notes as part of the UBL model).

X. The strategic horizon: ViDA and why “standards first” wins

The EU’s VAT in the Digital Age (ViDA) package, adopted 11 March 2025, codifies where Europe is going: structured einvoicing and digital reporting become the norm, especially for intra-EU B2B from 1 July 2030.

The Commission’s pages outline the policy arc and support for implementation; specialist summaries give businesses a clear sense of timing and scope. If you anchor on EN 16931/PEPPOL BIS now, you minimize future migration risk.

XI. Final take for PEB/EPC and property inspectors/certifiers

• Mandatory from 1 January 2026 (Belgium, domestic B2B): send/receive structured e-invoices via PEPPOL; the structured file is the only legally compliant invoice. PDFs may still accompany for readability but are not sufficient.

• Hermes sunsets on 31 December 2025: connect to a PEPPOL access point (usually via your invoicing tool).

• Scope nuances: B2C excluded; non-resident VAT-registered without Belgian fixed establishment excluded in 2026; otherwise, you are in scope.

• Format: EN16931/PEPPOL BIS Billing 3.0 (XML/UBL 2.1) with strict validation ensures seamless posting for your clients and cleaner VAT evidence.

• Roadmap: prepare for e-reporting (2028) and EU cross-border DRR (2030), choose tools that already speak PEPPOL.

If you do just one thing this quarter, make it this: adopt a PEPPOL-enabled invoicing tool and test real B2B flows with your top five clients. You’ll be compliant on day one, and you’ll likely notice faster payment cycles and fewer admin headaches long before the deadline.

Bibliography

1. E-Invoicing in Belgium: formal VAT requirements effective 2026 (Grant Thornton Belgium): confirms 1 Jan 2026 B2B mandate, structured invoice is the only legally compliant version.

Source: https://www.grantthornton.be/en/the-field/articles-and-publications/BTW/e-facturatie-en-formelebtw-vereisten-wettelijke-verplichtingen-vanaf-2026/

2. General questions about PEPPOL (Belgian government e-invoice portal): explains access points, PEPPOL IDs, and Hermes decommissioning on 31 Dec 2025.

Source: https://einvoice.belgium.be/en/FAQ/general-questions-about-peppol

3. PEPPOL BIS Billing 3.0 (official specification): rules, mappings, code lists; EN 16931 CIUS.

Source: https://docs.peppol.eu/poacc/billing/3.0/

4. European legislation on e-Invoicing (European Commission): Directive 2014/55/EU and EN 16931 overview.

Source:https://ec.europa.eu/digital-buildingblocks/sites/spaces/DIGITAL/pages/467108867/European%2Blegislation%2Bon%2BeInvoicing

5. Belgium will make B2B electronic invoice mandatory (EDICOM): vendor-neutral summary of 2026 obligation

and reliance on PEPPOL BIS/PEPPOL.

Source: https://edicomgroup.com/blog/belgium-will-make-b2b-electronic-invoice-mandatory

6. e-Invoicing in Belgium (EDICOM country page): confirms 2026 B2B mandate and 2028 near real-time ereporting.

Source: https://edicomgroup.com/electronic-invoicing/belgium

7. Belgium B2B e-invoicing—July 2024/2025 updates (VAT Calc): non-resident without Belgian fixed establishment excluded; timeline notes.

Source: https://www.vatcalc.com/belgium/belgium-b2b-e-invoicing-july-2024-update/

8. Adoption of the VAT in the Digital Age package (European Commission, 11 Mar 2025): cross-border timeline through 2030.

Source: https://taxation-customs.ec.europa.eu/news/adoption-vat-digital-age-package-2025-03-11_en

9. VAT in the Digital Age (ViDA) page (European Commission): implementation strategy and milestones to 2035.

Source: https://taxation-customs.ec.europa.eu/taxation/vat/vat-digital-age-vida_en