Self-billing in Belgium: complete 2026 guide

Do you regularly buy from many suppliers who do not issue their own invoices? Self-billing is the legal solution in Belgium for issuing invoices on their behalf. Widely used in agriculture, the automotive sector and distribution, it radically simplifies the commercial relationship with your suppliers.

This guide explains in detail the Belgian legal framework, the mandatory conditions, PEPPOL integration and the concrete cases where self-billing is the right answer.

What is self-billing?

Self-billing is a mechanism that reverses the roles in the classic invoicing process:

• Normal invoicing: the seller (supplier) issues the invoice and sends it to the buyer (customer).
• Self-billing: it is the buyer who issues the invoice on behalf of the seller, with their prior written agreement.

In practice, the buyer takes charge of creating the document, calculating VAT, sending it via PEPPOL and archiving it. The seller remains responsible for the VAT return, but no longer has to worry about the technical issuance of the invoice.

Concrete example: the agricultural sector

A Belgian dairy cooperative buys milk from 300 farmers every week. Imagine if each of them had to issue their own PEPPOL-compliant invoice:

• 300 invoices per week arriving in 300 different formats
• Frequent errors (VAT, mandatory statements, IBAN)
• Farmers often poorly equipped with accounting software
• Huge processing time on the cooperative's side

With self-billing, the cooperative itself issues the purchase vouchers (self-issued invoices) on behalf of each farmer. Single format, guaranteed compliance, automated process. The farmer receives their purchase voucher and payment — without any administrative task.

The same principle applies in automotive distribution (parts bought from small workshops), construction (subcontractors) or recurring B2B services.

The Belgian legal framework

Self-billing is perfectly legal in Belgium, governed by:

• Article 53 §2 of the Belgian VAT Code — main authorisation
• Royal Decree No. 1 of 29 December 1992 — technical details
• EU Directive 2010/45/EU — European harmonisation (all EU countries allow self-billing under similar conditions)

For a self-billing arrangement to be legally valid, several cumulative conditions must be met.

Mandatory conditions

1. Prior written mandate

Before any purchase voucher is issued, the buyer and the seller must sign a written mandate specifying:

• The full identity of both parties (company name, address, VAT number)
• The duration of the mandate (often annual, with tacit renewal)
• The types of transactions concerned
• The acceptance procedure (silence = acceptance after X days, generally 30)
• The dispute procedures available to the seller

This mandate must be kept for 7 years and presented in the event of a tax audit.

2. Mandatory statement on the document

Each purchase voucher (self-issued invoice) must include an explicit statement:

"Self-billing" or "Invoice issued by the customer in the name and on behalf of the supplier"

In Dutch: "Self-billing" or "Factuur uitgereikt door de medecontractant".

Without this statement, the document is not recognised as a valid purchase voucher by the tax authorities, even if all other details are correct.

3. Standard elements of any Belgian invoice

The purchase voucher must contain all the mandatory elements of a classic Belgian invoice:

• Unique sequential number
• Date of issue and due date
• VAT numbers of both parties (seller AND buyer)
• Precise description of the goods or services
• Taxable base, applicable VAT rate, VAT amount
• Total excl. VAT and incl. VAT
• Reference to the self-billing mandate (recommended)

4. Acceptance by the supplier

The supplier has a reasonable period (generally 30 days after receipt) to contest an incorrect purchase voucher. After this period, the document is deemed tacitly accepted and becomes fully enforceable.

5. Tax liability

Key point: the seller (supplier) remains responsible for the VAT return, even if it is the buyer who issued the document. Self-billing is an administrative delegation, not a tax one.

Special case: the special scheme for farmers

Many small Belgian farmers fall under the special scheme for farmers (Article 57 VAT Code). In this case:

• Self-billing is mandatory (not optional)
• VAT is flat-rate (generally 6% on primary agricultural products)
• Special statement required: "Special scheme for farmers — Article 57 of the VAT Code"
• The supplier (farmer) has no monthly VAT return obligation

If you buy from farmers under this scheme, your self-billing software must handle these specifics automatically.

Self-billing and PEPPOL

Since 1^st April 2026, B2B transactions between VAT-registered Belgian businesses must transit through the PEPPOL network. This includes purchase vouchers issued through self-billing.

Technically, a self-billing document sent via PEPPOL uses a specific UBL (Universal Business Language) format:

• InvoiceTypeCode 380 — classic invoice
• InvoiceTypeCode 389 — self-issued invoice (self-billed invoice)

Code 389 explicitly indicates to the receiving system that the document is a purchase voucher. The UBL structure must also include references to the self-billing mandate and the VAT identifiers of both parties.

Without this correct signalling, the document risks being rejected by the supplier's PEPPOL access point or reclassified as a non-compliant standard invoice.

Benefits of self-billing

For the buyer (the issuer)

• Total control over the format, VAT calculation and compliance
• Standardisation of all documents received from heterogeneous suppliers
• Huge administrative time saving (no more chasing missing or incorrect invoices)
• Shorter payment cycle (the document is ready as soon as the goods are received)
• Direct integration into accounting (WinBooks, Sage, Exact) with no re-entry

For the seller (the supplier)

• No administrative burden linked to issuing invoices
• No need for invoicing software or technical skills
• Automatic receipt of the validated document and payment
• Shorter payment terms (the buyer does not wait for the invoice to pay)

Limits and precautions

Self-billing also has some constraints to be aware of:

• Administrative mandate required — not usable for one-off or occasional transactions
• Shared responsibility in the event of an error (the buyer issues, the seller is fiscally responsible)
• Risk of dispute if the mandate is not signed correctly or if the seller's dispute is not tracked
• PEPPOL technical complexity — few software solutions natively handle InvoiceTypeCode 389

Who uses self-billing in Belgium?

The sectors where self-billing is the norm:

• Agriculture — dairy cooperatives, slaughterhouses, grain traders, purchases of primary products
• Automotive distribution — dealerships buying parts and services from small independent workshops
• Construction — general contractors with numerous subcontractors
• Copyright / royalty companies — payments to a large number of rights holders
• Large B2B platforms — marketplaces with thousands of third-party sellers

If you operate in one of these sectors and are still managing supplier invoices manually, self-billing can represent a considerable time saving.

How to set up self-billing?

1. Identify the suppliers concerned — those where volume justifies a mandate (typically 50+ transactions per year)
2. Draft and sign the written mandate with each supplier (template available from your accountant or industry federation)
3. Configure the invoicing software to generate purchase vouchers with InvoiceTypeCode 389 and the "Self-billing" statement
4. Enable PEPPOL transmission via a certified access point
5. Set up tracking of acceptances and disputes
6. Archive mandates and purchase vouchers for 7 years (Belgian legal obligation)

Self-billing at DEMFACT

The self-billing module is currently being developed at DEMFACT, at the request of several users in the agricultural and distribution sectors. It will include:

• Centralised management of mandates with each supplier
• Issuance of compliant purchase vouchers (automatic "Self-billing - Article 53 §2 VAT Code" statement)
• PEPPOL UBL format with InvoiceTypeCode 389
• Support for the special scheme for farmers (6% flat rate)
• Tacit or explicit acceptance workflow by the supplier
• Compliant accounting export (WinBooks, Sage, Exact)

If self-billing matches your needs and you would like to be notified when the module is available, contact us — you will be among the first users and will benefit from personalised support.

Conclusion

Self-billing is a powerful and perfectly legal tool for simplifying commercial relationships when you buy from many suppliers who have neither the time nor the means to issue their own invoices. Properly framed legally (written mandate, mandatory statements, PEPPOL compliance), it represents a huge productivity gain — particularly in the Belgian agricultural sector and in distribution.

With the PEPPOL obligation in force since 1^st April 2026, choosing software that natively handles compliant self-billing (InvoiceTypeCode 389, mandates, legal statements) becomes an essential criterion for high-volume B2B buyers.

Do you have questions about self-billing for your business? Our team will reply to you personally at support@demfact.com.