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Self-billing via Peppol in Belgium: the rules and how to get started

Published on 26 October 2026 · 4 min read
By Roberto Bilic, founder of BILIC

At a glance

Self-billing is still allowed in Belgium under the e-invoicing mandate that started on 1 January 2026. Two conditions apply: a prior agreement between customer and supplier, and an acceptance procedure for every invoice. The invoices go through Peppol, in a format made specifically for self-billing.

What is self-billing?

With self-billing, the customer issues the invoice instead of the supplier. The customer already knows what was delivered and how much is owed, so it makes sense for them to draw it up.

A few common examples:

a farming cooperative that invoices its members' milk or harvest from its own weighing records;
a platform that pays freelancers for jobs booked through it;
a main contractor that invoices its subcontractors based on hours worked or stages completed.

The supplier is still the one delivering the goods or services. Only the job of writing the invoice moves to the customer.

The two conditions set by the FPS Finance

The e-invoicing mandate did not change the rules. Self-billing remains allowed as long as:

both parties agree to it in advance. Put it in writing: who issues the invoice, based on which data, and how often.
the supplier accepts each invoice. The supplier must be able to check and approve every invoice. A one-time agreement at the start does not cover all later invoices.

How self-billing works over Peppol

Peppol has a separate format for self-billing, Peppol BIS Self-Billing. The difference from a regular invoice is the direction: the customer sends, the supplier receives.

Inside the file, software recognizes a self-billed invoice by its type code: 389 for an invoice, 261 for a credit note. That way both sets of books handle it correctly. The customer records it as a purchase, the supplier as a sale.

If the supplier disagrees with an invoice, they contact the customer, who issues a self-billed credit note or a new invoice.

Where the deadlines stand

A special grace period for self-billing ran until 30 June 2026 inclusive. A business that could show its software provider was still building the feature could send self-billed invoices another way in the meantime, without a fine.

That grace period is over. The FPS Finance can still decide not to impose a fine, but only in exceptional circumstances and after reviewing the individual case. It is not automatic.

Where to start

Ask your software provider whether it supports self-billing over Peppol, for both sending and receiving. As a customer you send; as a supplier you receive. If your software handles regular Peppol invoices, check separately that it also handles self-billing.
Put the agreement in writing with each supplier (or each customer) you self-bill with.
Agree on how each invoice gets accepted. For example: a deadline to raise an objection, who checks on the supplier's side, and what happens if there is a mistake.

Where the time savings are

With self-billing, most of the work sits in the acceptance step: checking each invoice, approving it, booking it. With dozens of suppliers or members, that adds up quickly. Automatic processing is not a legal requirement, but that is where the real time savings are: matching the invoice against your own records, tracking acceptance and preparing the bookkeeping entry.

For the general e-invoicing rules, see our article Peppol e-invoicing: what changes for Belgian SMEs. To automate acceptance and bookkeeping, see Save time.

Frequently asked questions

Can I still use self-billing under the e-invoicing mandate?

Yes. The rules have not changed. You need a prior agreement and an acceptance procedure for each invoice, and the invoice goes through Peppol.

Who sends the invoice over Peppol?

The customer. They issue the invoice in the supplier's name and send it to the supplier's Peppol address.

Does the supplier have to approve every invoice?

Yes, every invoice must go through an acceptance procedure. You decide together, in the agreement, what that procedure looks like.

My software can't handle self-billing over Peppol yet. What now?

The special grace period ended on 30 June 2026. If you are not ready yet, you can submit your situation to the FPS Finance, but avoiding a fine is not automatic. Talk to your software provider soon.

Sources

This article gives general guidance, not tax advice. Your accountant is the right person for your specific situation.