[BELGIUM] Can a customer refuse to pay an invoice because it was not sent through Peppol?

No. The mere fact that an invoice was not transmitted via Peppol is not, in itself, sufficient grounds for refusing payment.

Article 53, § 2bis of the Belgian VAT Code, introduced by the Act of 6 February 2024, requires the use of a structured electronic invoice for the B2B transactions concerned. This requirement relates to the invoicing method, but it does not affect the obligation to pay for goods or services that have been duly supplied or performed.

Where an invoice has not been transmitted in accordance with the electronic invoicing rules, the customer may ask the supplier to regularise the transmission. However, this irregularity alone does not render the invoice invalid and does not justify refusing payment.

Key point: compliance with the transmission channel requirements, including Peppol, and the obligation to pay a commercial debt are two separate legal obligations. The former concerns invoicing formalities, while the latter concerns performance of the contract.

Legal references:

• Belgian VAT Code, Article 53, § 2bis.
• Act of 6 February 2024 amending the Belgian VAT Code with regard to the introduction of mandatory electronic invoicing.