What if you still receive an invoice that wasn’t sent as an e-invoice?
As of January 1, 2026, the obligation for structured electronic invoicing (e-invoicing) between VAT-registered businesses in Belgium comes into effect. The goal is clear: all invoices must go through the secure Peppol network.
But what should you do if, in January 2026, you open your inbox and find a traditional PDF invoice from a supplier? Should you pay it? Can you still deduct the VAT? And do you risk a fine?
|
Step-by-step guide: How to handle non-electronic invoices from 2026
Don’t panic. Although the rules are changing, common sense (and a solid process) remains the foundation. Here’s what to do if you receive a “non-electronic invoice.”
Step 1: Basic check — Is the invoice VAT-compliant?
Regardless of the format (XML, PDF, or paper), the content requirements haven’t changed. Before taking any action, check whether the invoice is legally correct.
Make sure all mandatory information is included, such as:
The correct identity of the supplier and yourself as the recipient.
Accurate VAT numbers.
A valid invoice date and a unique invoice number.
A clear description of the goods or services delivered.
The correct VAT rate and amount.
Action: If essential information is missing, you must reject the invoice (protest) or request a credit note. This is independent of Peppol or e-invoicing; it’s basic accounting practice.
Step 2: Verify the origin (Authenticity)
Here is the major difference. With an electronic invoice guarantees the sender and ensures that the data hasn’t been tampered with. With a PDF sent by email, you don’t have that guarantee. Because the law aims to prevent fraud, you must personally verify the authenticity of any invoice that is not an e-invoice.
Check:
Does the sender’s email domain match previous correspondence?
Has the bank account number changed compared to previous invoices?
Does this invoice fit within the context of your business relationship?
This extra manual work is exactly why the government, and we at Banqup, strongly advocate Peppol: it eliminates these time-consuming checks.
Step 3: Can I deduct VAT?
Yes, but responsibly. Receiving an invoice outside of Peppol does not automatically mean you lose the right to deduct VAT.
The tax authorities will accept the deduction if:
The invoice is legally valid.
The underlying supply or service actually took place.
You act in good faith.
Note: In case of a tax audit, the burden of proof is on you. You must be able to demonstrate that you checked and processed the invoice according to the rules.
What You Absolutely Shouldn’t Do if You Receive an Invoice Not Sent via Peppol
It can be tempting to be strict, but avoid these pitfalls:
Ignoring the invoice: “No Peppol/UBL, so I do nothing” is not an option.
Refusing payment without communication: You cannot withhold payment without informing your supplier why (incorrect format).
Assuming it’s not your problem: The e-invoicing obligation applies to both sender and receiver. You must also be able to receive e-invoices.
What does the government expect from you if you don’t receive an e-invoice?
The government understands that January 1, 2026 marks a major transition. A grace period will apply.This means you may process exceptions, but you are not allowed to normalize them on a structural basis.
This is not a free pass to change nothing. In the case of repeated non-compliance, the tax authorities will expect you, as the customer, to address the issue with your supplier and actively encourage them to digitize.
Best practice: Your 3-phase action plan
So how should you handle this smartly in Banqup or your accounting software?
Short term (Transition phase):
Continue to process non-Peppol invoices as usual. Pay your supplier, but make sure you perform the additional checks (see Step 2). In your administration, it’s best to label these invoices as “exceptions.”Medium term (Education):
Does a supplier keep sending PDFs? Reach out.
Send a friendly but clear message, for example: “Dear supplier, we have received and processed your invoice correctly. However, in light of the 2026 legislation, we kindly ask that future invoices be sent as structured electronic invoices.”Long term (From Q2 2026 onwards):
Once the tolerance period has ended, it’s time to standardize the process. At that point, you can announce that non-compliant invoices will be rejected.
Conclusion: Banqup makes it easy
With Banqup, you’re prepared for both scenarios. You receive Peppol invoices directly and error-free. And if a PDF invoice still comes in, you can easily digitize it (via OCR) and process it in Banqup. This keeps your administration in one place, organized, compliant, and fully aligned with the legislation.
Not connected to Peppol yet? Activate your Banqup account today and be ready for 2026.
