Usually, yes. Whether you are self-employed full-time or in secondary occupation (alongside a job) makes no difference: what counts is your VAT status. Even under the VAT exemption scheme (art. 56bis, turnover up to €25,000) you are in principle in scope, according to the FPS Finance. Only businesses that exclusively carry out transactions exempt under article 44, or that exchange no invoices at all with Belgian VAT-registered businesses, are outside it.
Secondary or main occupation: it makes no difference
The official texts make no distinction between self-employment as a main or a secondary occupation. The FPS Finance applies a single criterion: if you have an active VAT number, the obligation applies to you too. If you invoice Belgian VAT-registered customers as a self-employed person in secondary occupation, you do so with a structured e-invoice. And you must be able to receive invoices from Belgian suppliers via Peppol.
The VAT exemption scheme (art. 56bis)
Under the exemption scheme you charge no VAT and file no periodic VAT returns, as long as your annual turnover stays under €25,000. But you remain VAT-registered and have a VAT number. That is exactly why the e-invoicing obligation applies to you.
In early 2026, media reports claimed that businesses under this scheme were not affected. On 7 April 2026 the FPS Finance responded: these taxable persons are in principle also subject to the obligation. In practice:
- invoices to Belgian VAT-registered customers go out as structured e-invoices (without VAT, with the legal mention of the exemption scheme);
- you must be able to receive invoices from Belgian suppliers via Peppol.
The FPS Finance says "in principle". Read elsewhere that you only need to be able to receive? Compare that claim with the official notice of 7 April 2026 (see sources) and discuss your situation with your accountant.
Who is outside the obligation?
- You only carry out transactions exempt under article 44 of the VAT Code: then you do not have to send or receive. If you also carry out taxable transactions, the obligation applies to those.
- You exchange no invoices at all with Belgian VAT-registered businesses: then, according to the FPS Finance, the obligation does not apply.
- You are not a taxable person for VAT: the obligation does not apply between a VAT-registered business and someone who is not.
Note: "not VAT-registered" and "exempt under the exemption scheme" are not the same thing. If you use the exemption scheme, you are VAT-registered. In doubt? Check in the Crossroads Bank for Enterprises whether "Subject to VAT" appears under your capacities.
Overview: sending and receiving
| Your situation | Send via Peppol | Receive via Peppol |
|---|---|---|
| VAT-registered, customers are Belgian VAT-registered businesses | Yes | Yes |
| VAT exemption scheme (art. 56bis), business customers in Belgium | Yes, in principle | Yes |
| Only private customers, but Belgian suppliers | No | Yes |
| Only transactions exempt under art. 44 | No | No |
| Not VAT-registered | No | No |
What to do if you are in scope
The same as any other business, just often on a smaller scale. Choose a Peppol tool whose price fits the number of invoices you make, check that it covers both sending and receiving, and get registered on your enterprise number. The full steps are in our guide to the Peppol obligation; receiving is covered in our guide to receiving Peppol invoices for free; the practical side is in our guide to sending and receiving, in Dutch or French.
As a sole trader you can deduct 120% of the cost of a subscription to e-invoicing software for the taxable periods 2024 to 2027. Ask your accountant how this works in your tax return.
Frequently asked questions
I only make a few invoices a year. Do I still have to comply?
The number of invoices plays no role. Even a single invoice to a Belgian VAT-registered customer must be a structured e-invoice.
I am a self-employed student. Does this apply to me?
Yes, if you have an active VAT number and invoice or buy from Belgian VAT-registered businesses. Your social security status is not a criterion.
My accountant says I only need to be able to receive. Who is right?
On 7 April 2026 the FPS Finance wrote that taxable persons under the exemption scheme are in principle subject to the obligation, without limiting it to receiving. Give your accountant that notice and decide together.
I only work for private customers. Do I need to do anything?
You do not have to send those invoices via Peppol, but you must be able to receive Peppol invoices from your Belgian suppliers.
Do I show VAT on my Peppol invoice under the exemption scheme?
No, you charge no VAT. Your invoice does include the legal mention that the exemption scheme applies. Your software must put it correctly in the Peppol invoice.
Official sources
Every fact in this guide comes from the sources below, checked on 01/11/2026. Some official pages only exist in Dutch, French or German; we link the French version.
- FPS Finance – Who is the e-invoicing obligation for? (in French)
- FPS Finance – End of the general tolerance period (07/04/2026) (in French)
- FPS Finance – General questions about the B2B obligation
- FPS Finance – VAT franchise scheme (art. 56bis) (in French)
- FPS Finance – Tax incentives for adopting e-invoicing (in French)
- Law of 6 February 2024 (Belgian Official Gazette, 20/02/2024)
This guide is general information, not legal or tax advice. If you are unsure about your situation, ask your accountant or the FPS Finance.
More guides
- Peppol mandatory in BelgiumWho is in scope, the fines, and 5 steps
- Receive Peppol invoices for free?Who must receive, Hermes, and your options
More guides in Dutch and French
Two more Peppol guides (sending and receiving step by step, and what to do when a customer asks for a Peppol invoice) are available in Dutch and French.
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