Vintro Pro Knowledge base · VAT & admin

Peppol e-invoicing: does it apply to you?

This page describes Belgian law, in force since 1 January 2026. If you invoice from the UK, this particular obligation is not yours — but the Peppol format itself is international, and the margin-scheme codes further down are not Belgian either.

Written by Griet Coussement, founder of Vintro Pro and Vintiques Export

Which law? This page follows the Belgian rules. The Netherlands, France and the UK differ — you will find the comparison further down this page.

It depends on who you sell to. Not on what you sell.

Since 1 January 2026, Belgian VAT-registered businesses have had to use structured electronic invoices between one another. A pdf by email no longer counts — the invoice travels straight from one piece of software to another, over the Peppol network.

An invoice to a Belgian business

No longer counts

You

A pdfYou make the invoice as a file.

On the way

By emailAs an attachment to your customer.

Your customer

An attachmentNot a structured invoice.

Since 1 January 2026

You

Your softwareThe invoice leaves in structured form.

On the way

PeppolThe network between the packages.

Your customer

Their softwareStraight from one piece of software to another.

Selling to a private customer? Then that invoice falls outside it.

That sounds like it affects everyone. In practice it hangs on one phrase: between one another. The obligation runs between businesses. Sell to a private customer and that invoice falls outside it.

Sale to a private customer → no Sale to a Belgian business → yes

The short version, in three cases

Hold your own sales up against these three and you will know straight away:

case 1 · a customer in the shop

No

A private buyer takes a cabinet. The government site is explicit: invoices to private customers are not covered. For most antiques dealers that is the bulk of turnover.

case 2 · a Belgian colleague

Yes

You pass a piece on to another Belgian dealer with a VAT number. This is the sale that does fall under the obligation, and precisely the one a dealer overlooks.

case 3 · a dealer abroad

No

VAT payers with no fixed establishment in Belgium sit outside the Belgian obligation. A sale to a brocanteur in Lille is not covered by it — though his own country may ask for something else.

Selling mostly to private customers, little changes for you. Selling on to colleagues regularly, it does.

The catch: being small does not help

This is where the mistake is made most often. Anyone under the small business exemption scheme — the one that lets you charge no VAT below a turnover of 25,000 euros (26,000 euros from 2027) — tends to assume the obligation is not theirs.

It is. The obligation covers all VAT-registered businesses, and that scheme does not make you any less VAT-registered. Below the exemption threshold too, your invoice to a Belgian business has to leave in structured form.

No turnover threshold. If you hold a VAT number and invoice a Belgian business, you are covered.

What counts, and what does not

Changes nothing

Being small Below 25,000 euros turnover (26,000 from 2027), the obligation stays.

What counts

VAT number + a Belgian business customer Then your invoice has to leave in structured form.

The exemption scheme does not make you any less VAT-registered.

Who genuinely falls outside it

There are exceptions, but few, and narrowly drawn:

Sources and checks

Source: efactuur.belgium.be, the Belgian federal government's own site. Checked on 30 August 2026. This is an explanation, not tax advice — put your own situation to your accountant.

And across the border?

Everything above is Belgian law. The picture elsewhere is quite different — and France has started: since 1 September 2026 every VAT-registered business there must be able to receive an electronic invoice, whatever its size.

The UK card below is grey on purpose. HMRC does not yet require a structured e-invoice between businesses; the government has announced one for all VAT invoices from 2029. Until then, if you invoice from the UK this does not reach you — but it does reach the invoice you send to a Belgian or French dealer.

UK not yet required, mandatory from 2029 announced

the government has announced mandatory e-invoicing for all VAT invoices from 2029

BE mandatory since 1 Jan 2026

between VAT-registered businesses, over Peppol

FR receiving from 1 Sep 2026

binds businesses established in France; issuing from 1 Sep 2026 only for large businesses and ETIs (intermediate-sized), from 1 Sep 2027 for SMEs and micro businesses

NL no obligation

permitted, but only with the buyer's consent

Sources, each checked on 30 August 2026: efactuur.belgium.be (Belgium) and impots.gouv.fr (France, Je découvre la facturation électronique); the French timetable also in loi no. 2023-1322, art. 91, III, A, checked on 30 October 2026. For the Netherlands: no B2B mandate found, but a stated intention towards 2030. For the UK: gov.uk, government response to the consultation Promoting electronic invoicing across UK businesses and the public sector (26 November 2025), checked on 7 October 2026.

Two things worth knowing. France does not run on Peppol but on state-approved platforms. And ⚠️ the French obligation binds businesses established in France — a seller established elsewhere does not have to issue an electronic invoice to a French customer. Literally on impots.gouv.fr: « le volet e-invoicing de la réforme … ne concerne pas les entreprises étrangères sans établissement stable en France ». With a permanent establishment in France, or where you are liable for French VAT yourself, it differs — put that to your accountant. Checked on 31 August 2026.

What, when, per country

  1. BE 1 January 2026 Mandatory between VAT-registered businesses, over Peppol.
  2. FR 1 September 2026 Every VAT-registered business receives; only large businesses and ETIs (intermediate-sized) issue as well.
  3. FR 1 September 2027 SMEs and micro businesses issue too.
  4. BE 1 January 2028 End of the postponement for the flat-rate scheme.
  5. UK 2029 Announced: e-invoicing for all VAT invoices. Not yet required today.
  6. NL No obligation Permitted, but only with the buyer's consent.

France runs on state-approved platforms, not Peppol, and binds businesses established in France.

A margin invoice inside Peppol

The question a second-hand dealer asks immediately: does a margin sale even fit into an invoice that standardised? A paper invoice has to state that the special scheme applies: “Bijzondere regeling - gebruikte goederen” (Royal Decree no. 53, art. 8).

The answer is: half. Peppol BIS Billing 3.0 works with VAT categories, and the margin scheme sits under category E. Three exemption codes name the margin scheme in so many words — but read their title, not only their description:

VATEX-EU-Fsecond-hand goodsIntra-Community acquisition of second hand goods
VATEX-EU-Iworks of artIntra-Community acquisition of works of art
VATEX-EU-Jcollectors’ items and antiquesIntra-Community acquisition of collectors items and antiques
Sources and checks

Source: the official Peppol BIS Billing 3.0 code list, May 2026 Release (docs.peppol.eu), read word for word on 11 September 2026. The third column is the title exactly as it stands on that page. These codes belong to the Peppol format, not to the law of any one country. VATEX-EU-D (second-hand means of transport) is not one of them: that code says VAT was paid under the transitional arrangements, not that the margin scheme was applied. Checked on 7 October 2026.

⚠️ The list holds no code for a purely domestic margin sale. Sell a cabinet under the margin scheme to a dealer in your own country and none of the three fits precisely: their titles all describe an intra-Community acquisition, a purchase from another member state. The description underneath simply says the margin scheme has been applied, without that restriction. Title and description contradict each other, and that is an ambiguity in the standard itself.

What is certain: the VAT category is E — all three codes state plainly “Only use with VAT category code E”. And on category E the exemption needs a reason. With no code that fits, that written reason is what remains: exactly what your margin invoice already had to carry on paper.

Ask your software or your accountant which code they use. Picking a code yourself that is only nearly right comes back as a rejected invoice.

What goes wrong for a second-hand dealer

Not the technology. Four things we see in practice:

"I sell to private buyers anyway"

Usually true. But that one cabinet going to a colleague, or the lot you pass on after a house clearance, is a B2B sale — even though the work felt identical.

"I'm under the small business scheme"

The most common mistake. Charging no VAT is not the same as not being VAT-registered. The obligation applies from the first euro.

"My accountant handles that"

Your accountant processes invoices; they are not the one raising them at the moment of sale. The invoice has to leave in structured form, and that happens in whatever you invoice from.

No error appears

A pdf by email goes out just fine. The recipient does not complain. You find out at an inspection — exactly the pattern of everything that quietly stalls in admin.

Fines are provided for. The amounts sit in the implementing decrees rather than on the government's public site; we deliberately do not repeat them here from second-hand sources. Ask your accountant.

How Vintro Pro solves this

Vintro Pro does not send Peppol invoices itself — deliberately. The route runs through the accounting software you already work in.

With Odoo: you put sold items in the invoice basket and the app raises a draft invoice in your own Odoo. Not in ours — the connection is configured per dealer. Odoo then sends over Peppol, and picks up incoming Peppol invoices as well.

With Falco (Belgium): Vintro Pro hands the invoice to your Falco. Falco sends it over Peppol to your customer and files it in Horus. Margin-scheme goods go under VAT category E. You need Falco Expert for this.

What that looks like in the app is set out step by step in Creating an invoice.

One route to every package. That is exactly what Peppol exists for — and why no seven separate integrations get built here.

If you do not yet work with accounting software that speaks Peppol, that is the conversation to have with your accountant before you invoice your next sale to a colleague.

Your invoices and your stock in one place?

Vintro Pro creates your sales invoice from the very piece in your stock — with the right VAT wording on it.

Frequently asked questions

Do I have to invoice through Peppol since 2026?

This is Belgian law, and it covers only sales to another Belgian VAT-registered business. Since 1 January 2026 those invoices must leave in structured electronic form, over the Peppol network. Invoices to private customers are not covered. If you invoice from the UK, this particular obligation is not yours.

Does it apply under the small business scheme (25,000 euros in 2026, 26,000 euros from 2027)?

Yes. The obligation covers all VAT-registered businesses. The small business exemption means you charge no VAT, not that you are not VAT-registered. There is no turnover threshold.

Do I have to send an invoice to a French or Dutch dealer over Peppol?

Not under the Belgian obligation: VAT payers with no fixed establishment in Belgium fall outside it. Their own country may ask for something else, so check with your accountant.

Can a margin sale fit in a Peppol invoice?

Yes, under VAT category E. But the three codes that name the margin scheme — VATEX-EU-F, -I and -J — all carry the words intra-Community acquisition in their title. For a purely domestic margin sale the list holds no code at all. What remains is category E with the reason written out. Ask your software or your accountant which code they use.

Who falls outside the obligation?

Taxable persons in a state of bankruptcy, those carrying out only transactions exempt under article 44 of the VAT code, VAT payers not established in Belgium with no fixed establishment there, and taxable persons under the flat-rate scheme — the last of those until 1 January 2028.