Belgium's 2028 E-Reporting: The Five-Corner Model, and Why Both Sides Report

Belgium plans to make businesses report invoice data to the tax administration in near real time from 1 January 2028, and both the supplier and the customer will generally report the same invoice. The rule is still a draft: the federal Council of Ministers approved a preliminary draft law on 18 July 2026, and Parliament has not yet voted on it. It builds on the Peppol e-invoicing obligation in force since 1 January 2026 and abolishes the annual customer listing for businesses it covers.

This page is for the finance lead at a Belgian business, and for the owner of a Belgian online shop that sells to other businesses. It sets out what the 2028 obligation is, how far the law has got, who reports which invoices, and what is worth doing now. It does not cover penalties or the technical data fields, which Belgium has not yet published.

Is Belgian e-reporting law yet?

No. It is a preliminary draft law, approved by the federal Council of Ministers on 18 July 2026.

The decision was taken on a proposal by Finance Minister Jan Jambon. The text amends the VAT Code to bring in an electronic reporting obligation and to abolish the annual customer listing. The government's own release (Dutch, French) says the draft was then sent for advice to the Data Protection Authority and the Council of State, before going through the rest of the legislative process.

That process ends in the Chamber of Representatives. The 2026 e-invoicing obligation went the same way: the official e-invoicing portal records that the Chamber formally adopted that law in February 2024, almost two years before it applied.

On 18 October 2026 we checked the official portal and found no announcement that the 2028 law had been passed. Until it is, three things can still change: the start date, the scope, and the detail of what is reported. The draft already makes the direction clear, and the 2028 date has been the government's stated plan since the 2025–2029 federal coalition agreement.

What is not known yet. The exact reporting deadline behind "near real time", the list of data fields, how corrections are reported and the technical specifications have not been published. Anything you read that gives an exact number of hours or a field list for Belgium is ahead of the official texts.

Who has to report, and on which invoices?

Under the draft, both parties to a domestic business-to-business invoice report it: the supplier and the customer.

KPMG Belgium summarises the draft this way: businesses "will also need to report selected invoice data to the Belgian VAT authorities in near real time from 1 January 2028", and "both suppliers and customers will generally be required to report". It names three areas with their own rules:

• VAT groups.
• Supplies to non-Belgian customers that hold a Belgian VAT number.
• Transactions under the special scheme for farmers.

The reporting sits on the same transactions that the 2026 B2B e-invoicing obligation already covers. Those are invoices between businesses established in Belgium, exchanged as structured Peppol documents. Sales to private consumers are outside the 2026 obligation, and the published summaries of the 2028 draft do not describe them as in scope either. Treat that as the current reading of a draft, not a final answer.

Two consequences follow for anyone planning systems:

1. Your purchase invoices matter as much as your sales invoices. As a customer, you report invoices you did not create and cannot change. If your inbound invoices still arrive in a mailbox that someone works through at month end, that becomes a reporting gap.
2. Your counterparty's report and yours will be compared. A mismatch, or a report on one side with nothing on the other, is visible to the administration in days rather than at the end of the year.

What replaces the annual customer listing?

For businesses inside the e-reporting obligation, nothing does: the draft abolishes the listing, because e-reporting already gives the administration the same data.

The annual customer listing is the yearly return in which a Belgian VAT-registered business lists its Belgian VAT-registered customers and the turnover with each. Its purpose is cross-checking: the administration compares what a supplier says it sold with what customers declare.

E-reporting does that cross-check continuously, invoice by invoice, and with both sides reporting. The government's release says the abolition applies to taxpayers subject to the new obligation. Businesses outside it, for example where special rules apply, should not assume the listing disappears for them until the final text says so.

What is the five-corner model?

It is the familiar four-corner Peppol exchange with the tax administration added as a fifth participant that receives invoice data as the invoice moves.

The four-corner model most people know:

C1 supplier → C2 supplier's provider → C3 buyer's provider → C4 buyer

The invoice travels between two certified access points, and the tax authority sees nothing until a return is filed.

The fifth corner adds the administration:

C1 → C2 → C3 → C4
      ↘         ↙
        C5  tax authority

Commentators describe Belgium's proposal as a Peppol-based five-corner model, with the administration receiving structured transaction data. Reporting stops being a monthly or annual summary and becomes part of the transaction itself. Belgium has not yet published the specification of how the data reaches it, so read the diagram as the shape of the model rather than as Belgium's final message flow.

Why do both the supplier and the customer report?

Because two independent reports of one invoice can be matched, and one cannot.

If only the supplier reported, the administration would hold one unverified statement per invoice. With both parties reporting independently, it holds two records of the same transaction from two different systems. A mismatch is a signal. A missing counterpart is a signal.

That is what makes the model a fraud-detection instrument rather than a faster filing cabinet. It is also why the annual customer listing becomes redundant: the matching the listing allowed once a year now happens continuously.

The practical consequence: your provider must file correctly on both legs. If you are the buyer, your provider reports on invoices your supplier created. Getting that right is a different problem from sending an invoice.

Where does this model already run?

Oman runs the same dual-reporting design, and GoRoute files to it.

Oman's e-invoicing framework, set out in the Tax Authority's Solution Reference Architecture (v1.0.3, July 2026), has the supplier's access point and the buyer's access point each file a Tax Data Document for the same invoice. The two filings are matched by a version 5 UUID that both sides derive from the same fields of the invoice, under a namespace fixed by the specification. So the authority can pair the two reports without the two providers ever talking to each other. Two independent reports, one transaction, matched by construction.

GoRoute is a certified Peppol access point (POP000991). Since Oman's live tax-reporting endpoint opened in September 2026, we have filed Tax Data Documents to it from the supplier's side and from the buyer's side. Oman's five-corner model explained walks through the flow, and our Oman page covers the regime.

What transferred from that work: the hard part is not sending to a fifth corner. It is making both filings agree when two different systems, in two different companies, produce them from the same document. A deterministic identifier is what makes that workable. Timestamps, ordering and retries are where it goes wrong.

Belgium has not said whether it will match on a derived identifier as Oman does. That is our reading of what the design needs, not a published Belgian rule.

What does 2028 e-reporting mean for an online shop?

If your shop sells to Belgian businesses, the invoices it already sends over Peppol are the ones that will be reported, and the shop is a customer too.

Since 1 January 2026 a Belgian shop has had to send structured e-invoices to its business buyers, as our guide for Belgian online shops explains. The 2028 draft adds a report of those same invoices. A shop that already sends every business order as a Peppol invoice, through a certified access point, has the data the report needs.

Three things to check in your shop now:

• Every business order produces a Peppol invoice, and every refund a credit note. A report cannot be more complete than the invoices behind it. On WooCommerce in Belgium and on Wix, the GoRoute apps raise the invoice when payment completes and the credit note when you refund.
• Your business buyers' enterprise numbers are right. Belgian participants are addressed on scheme 0208. A wrong number breaks delivery today and will break matching in 2028.
• Your own purchase invoices arrive over Peppol, not by email. Your suppliers will report what they sold you. As a customer, you will report it too. Receiving your suppliers' e-invoices in Belgium covers that side.

Consumer orders are not in the 2026 obligation, and the published summaries of the draft do not put them in the 2028 one either. Nothing about a consumer checkout needs to change for this.

Do providers need accreditation?

Nothing published so far creates an accreditation regime for providers in Belgium.

France has a register of approved platforms, and the choice of provider is limited to it. Belgium did not build that for the 2026 obligation. FPS BOSA publishes a list of compliant software that developers ask to join, but it is not a licence. The 2028 draft has not been described as adding one.

For Belgium, your provider needs to be a certified Peppol access point that can file both sides correctly. It does not need a Belgian licence, and, as foreign companies often ask, it does not need to be a Belgian company.

What should you do now, in 2026?

You do not need to build for 2028 today. You do need to avoid choices that make it expensive.

• Keep the invoice identity stable and derivable. If an invoice's identity is a database sequence only your system knows, matching two independent filings later will be painful.
• Store the document you actually sent, byte for byte. Reporting a transaction you can no longer reproduce is not a position you want to be in.
• Treat inbound as a first-class path. In 2028 the buyer has its own obligation. An inbound process that is a mailbox someone checks becomes a compliance gap.
• Ask your provider whether it has done dual filing anywhere. The answer is either yes, with a jurisdiction attached, or a roadmap.
• Watch ViDA. From 1 July 2030 the EU's VAT in the Digital Age package brings digital reporting for intra-Community transactions. Belgium is early, not unique, and building for Belgium properly covers much of the rest.

Next steps

• Talk it through with us. Book a session and we will walk your invoice and purchase flows against the 2028 draft.
• Selling online? Start with WooCommerce e-invoicing in Belgium or the Wix app. Both are free for the first fifty e-invoices a month.
• Building it yourself? The document types, statuses and identifier formats are in the developer documentation, and recorded walkthroughs are on tutorials.
• Read next: Belgium B2B e-invoicing 2026, the obligation the 2028 reporting sits on.

Related reading

• Belgium e-invoicing compliance: the current mandate, in full
• Does your Belgian online shop have to send e-invoices?: the 2026 rule for webshops
• Receiving your suppliers' e-invoices in Belgium: the inbound side
• Oman's five-corner model explained: the same shape, running today
• E-invoicing mandates 2026 tracker

Primary sources: Belgian federal government release of 18 July 2026 (NL, FR) · einvoice.belgium.be (FPS BOSA and FPS Finance) · European Commission, eInvoicing in Belgium · KPMG Belgium, "E-invoicing today, e-reporting tomorrow" · Oman Tax Authority and OpenPeppol, Oman Solution Reference Architecture v1.0.3 (2026-07-27).

The 2028 regime is at preliminary draft law stage. Details can change before it is enacted. Where this article describes the proposal rather than settled law, it says so. Last checked against the official sources on 18 October 2026.