Belgium E-Invoicing: Are VAT-Exempt Businesses and Small Franchisees Excluded?

Our Belgium complete guide covers the headline rule: there's no size-based exemption from Belgium's B2B e-invoicing mandate — every VAT-registered business established in Belgium is in scope, regardless of turnover. That's true, but it isn't the whole story. Two specific categories of business sit outside the sending obligation for a different reason: not their size, but the VAT status of what they sell.

Article 44: Exempt Activities, Not Exempt Businesses

Under Article 44 of the Belgian VAT Code, certain activities — including many medical, financial, insurance, and educational services — are exempt from VAT altogether. Businesses that exclusively carry out these exempt activities fall outside the B2B e-invoicing mandate's sending obligation, because the mandate is built around structured invoicing for VAT-taxable transactions. If you never charge VAT on what you sell, there's no VAT-relevant structured invoice to send in the first place.

This is a narrower exemption than it might sound: it applies to the specific transactions that qualify as exempt under Article 44, not to a business's entire operation. A company that carries out both exempt and taxable activities is still in scope for the taxable side of what it does.

The Small Business (Franchise) Scheme: Under €25,000 Turnover

Separately, Belgium's VAT exemption scheme for small businesses (franchise de la taxe / vrijstellingsregeling kleine ondernemingen) lets businesses with annual turnover not exceeding €25,000 (excluding VAT) opt out of charging VAT entirely. Businesses operating under this franchise scheme are likewise not required to issue structured B2B e-invoices for their franchise-covered sales, for the same underlying reason as Article 44: there's no VAT being charged on the invoice.

Don't confuse this with the general mandate's lack of a size threshold. The complete guide is correct that Belgium applies its mandate without a company-size phase-in — a large business doesn't get more time than a small one. The franchise scheme exemption is different: it's tied to VAT-exempt status, not a grace period based on size, and it stops applying the moment turnover crosses €25,000 and the business must register for standard VAT.

The Part Businesses Miss: You Likely Still Need to Receive

Here's the detail that catches exempt businesses and franchisees off guard: being exempt from sending doesn't exempt you from receiving. Your suppliers — assuming they're VAT-registered businesses subject to the mandate — are still obligated to send you structured Peppol e-invoices for what they sell you, and the mandate's receiving obligation applies to any Belgian-established, Peppol-registered business regardless of whether its own outbound sales are exempt.

In practice, this means:

A small franchisee that buys supplies from a mandate-covered Belgian business will typically still need a Peppol-compliant way to receive invoices, even though its own sales stay exempt from the sending requirement.
A medical practice invoicing exclusively exempt healthcare services doesn't need to issue Peppol invoices to patients or other businesses for that care — but if it buys equipment or services from a Belgian VAT-registered supplier, that supplier may still send the invoice as a structured Peppol document.

What This Means in Practice

Check which of your specific revenue streams are exempt, not just whether your business "feels small" — Article 44 exemption is activity-based, and mixed-activity businesses need to track which invoices fall inside vs. outside the mandate.
Don't assume franchise or exempt status means you can ignore Peppol entirely — set up at least a basic receiving capability, since your suppliers' obligations don't disappear because you're exempt.
Re-check your status if turnover approaches €25,000 — crossing the franchise threshold moves you from exempt to fully in-scope, including the sending obligation, from the point you register for standard VAT.

Frequently Asked Questions

Q: If my business is Article 44-exempt, do I ever need to issue a Peppol invoice? A: Not for your exempt activities. If you also carry out any VAT-taxable side activities, those invoices remain in scope.

Q: Does the €25,000 franchise threshold get indexed or change over time? A: The threshold is set in Belgian VAT law and can change by legislative amendment; always confirm the current figure with FPS Finance rather than relying on a fixed number indefinitely.

Q: Can I stay on the franchise scheme and still choose to send Peppol invoices voluntarily? A: Nothing in the mandate prevents voluntary Peppol adoption — some franchisees do this anyway to simplify dealing with business customers who prefer structured invoices.

Last updated: September 2026. We track official sources (FPS Finance, the Belgian e-invoicing FAQ, and the European Commission's eInvoicing knowledge base) and update this guide when the rules change.