Invoicing between Belgium and the Netherlands in 2026: cross-border PEPPOL, VAT reverse charge, and what ViDA changes

Belgian and Dutch markets live next to each other, and a growing share of SMEs on both sides invoice across the border. But the two countries do not have the same e-invoicing rules, nor the same VAT treatment for cross-border transactions. In October 2026, nine months into the Belgian B2B PEPPOL mandate, the picture is clearer than ever — and the ViDA package has set a new EU-wide clock running toward 2030. Here is what you actually need to know.

Where each country stands in October 2026

The two mandates have evolved at different speeds, so a cross-border invoice sits at the intersection of two separate rulebooks:

Belgium: domestic B2B e-invoicing via PEPPOL BIS Billing 3.0 is mandatory since 1 January 2026. The three-month tolerance period ended on 31 March 2026, and since 1 April 2026 the progressive penalty regime applies — EUR 1,500, then 3,000, then 5,000 euro per repeat offence.
Netherlands: B2G e-invoicing has been mandatory since 2017. Central government bodies receive via Digipoort or PEPPOL, in SI-UBL 2.0 or PEPPOL BIS 3.0. B2B e-invoicing is not yet mandatory but widely adopted via PEPPOL. In March 2026 an advisory report was submitted to the Dutch Parliament recommending a nationwide B2B framework based on PEPPOL; a formal government response is expected during summer 2026, followed by a public consultation on draft legislation in Q4 2026.

The practical consequence: a Belgian supplier must send PEPPOL by default for domestic B2B; a Dutch supplier is not yet forced to, but the capability is becoming common.

PEPPOL BIS Billing 3.0 vs SI-UBL 2.0 — do you need both?

Both formats implement the European standard EN 16931 on top of UBL 2.1. The practical differences are:

PEPPOL BIS Billing 3.0 is the pan-European baseline used everywhere PEPPOL is enabled. In Belgium it is the official required format from 1 January 2026.
SI-UBL 2.0 is the Dutch national variant maintained by Logius. It is a superset of EN 16931 with Dutch-specific extensions (e.g. detailed order and delivery references, extra VAT scheme codes used by Dutch public bodies).

If you are a Belgian supplier sending to a Dutch client, PEPPOL BIS 3.0 is perfectly accepted — your access point delivers it to the recipient's PEPPOL ID (participant ID, usually 0106 for KvK or 9944 for BTW) and that is enough. You do not need to issue SI-UBL 2.0 unless the Dutch customer explicitly requires it (typical for Dutch government contracts).

VAT: reverse charge is almost always the right answer

This is the point every freelancer and SME keeps getting wrong. For B2B services between two VAT-registered businesses in different EU Member States, EU VAT Directive 2006/112/EC applies:

Article 44: the place of supply is where the customer is established.
Article 196: therefore the VAT is accounted for by the customer, not the supplier.

Concretely:

A Belgian consultant invoicing a Dutch BV charges 0% VAT and must include the mandatory wording: "Reverse charge — VAT due by the recipient — Article 44 of Directive 2006/112/EC". The Dutch BV reports and self-accounts the VAT in its own BTW return.
A Dutch zelfstandige invoicing a Belgian BV: mirror situation. 0% VAT, same reverse charge wording. The Belgian company self-accounts BTW in its periodic declaration.
Both parties must have valid, verified VAT numbers (BE 10 digits, NL BTW-id in the new format NL XXXXXXXXXB01) — check them in VIES at ec.europa.eu/taxation_customs/vies.

Goods are different: intra-EU B2B supplies of goods benefit from a 0% VAT exemption under Article 138 (not reverse charge in the same sense), with mandatory listing in the EC Sales List / Opgaaf ICP. Services under Article 44 are what the vast majority of cross-border freelance invoices look like.

What a correct BE → NL (or NL → BE) PEPPOL invoice contains

A cross-border invoice is still a PEPPOL invoice. The practical checklist:

Your own VAT number and legal information, exactly as registered.
The customer's full VAT number (NL...B01 or BE0...) — verified in VIES, not just copy-pasted.
The customer's PEPPOL participant ID. For Dutch customers that is usually 0106 + KvK (Chamber of Commerce) or 9944 + BTW; for Belgian customers it is 0208 + CBE/BCE number or 9925 + VAT.
VAT category code K or AE on each line, depending on your access point's mapping — both indicate reverse charge in EN 16931.
The exact legal note on the invoice: "Reverse charge — VAT due by the recipient — Article 44 of Directive 2006/112/EC".
Total VAT = 0.00 EUR, with VAT breakdown lines showing the reverse-charged amount.

If any of these are missing, the recipient's accountant will reject the invoice or, worse, pay it and then have a problem reclaiming the (incorrectly charged) VAT.

ViDA: the 2030 clock has already started

The VAT in the Digital Age (ViDA) package was formally adopted by the EU Council on 11 March 2025 and entered into force on 14 April 2025. The implications most people miss:

Since April 2025: Member States can mandate domestic e-invoicing without needing a derogation from the Commission, and customer consent for e-invoices is no longer required. This is exactly what let Belgium start on time.
1 July 2030: cross-border B2B transactions inside the EU will fall under harmonised Digital Reporting Requirements (DRR). Invoice data must be reported by the supplier in near real time, within 10 days of the chargeable event, in a standardised EN format.
1 January 2035: Member States that already run their own real-time reporting systems must align with the EU standard.

In other words: the paper VIES-based intra-EU control system is being quietly replaced by near-real-time digital reporting. If your business already sits inside PEPPOL today, you are on the right side of that transition — the format is the same, only the reporting layer gets added on top.

What to do today, if you invoice across the border

Verify every cross-border VAT number in VIES before you issue the first invoice to that customer.
Check that your invoicing software can handle PEPPOL BIS 3.0 cross-border, with VAT category AE and the Article 44 note on the invoice (not only as a PDF watermark — it must be in the UBL).
Store the customer's PEPPOL ID the moment you capture them; it saves time on every future invoice.
Keep an eye on the Dutch B2B consultation expected in Q4 2026 — if you work regularly with Dutch customers, the format and timeline will matter.

DEMFACT handles the Belgian B2B scope and cross-border PEPPOL invoicing out of the box: a Belgian user invoicing a Dutch client in DEMFACT today sends a compliant BIS 3.0 invoice with the correct Article 44 note and VAT breakdown, through a certified access point. For Dutch suppliers invoicing Belgian clients, the same flow works in reverse — the format is PEPPOL, the VAT rules follow Article 44/196, and the invoice lands directly in the Belgian recipient's PEPPOL inbox.