Will e-invoicing also be mandatory for medical professions from 2026?

From Jan. 1, 2026, sending and receiving electronic invoices via the PEPPOL network will become mandatory for all companies subject to VAT in Belgium that conduct B2B transactions.

But what does this mean for the medical professions? If you only perform therapeutic activities, you are a fully exempt taxpayer and are not subject to the obligation. However, often, as a medical professional, you are registered as a mixed taxpayer who also performs non-therapeutic activities, albeit often exceptionally, and opted for the small business exemption scheme for those activities.

In this article, we provide more clarity and tell you why joining PEPPOL is always a smart move.

What is the e-invoicing requirement as of Jan. 1, 2026?

As of Jan. 1, 2026, e-invoicing will become mandatory for all VAT liable companies in Belgium that B2B transactions perform. E-invoicing is the process by which fully digital purchase and sales invoices (without manual intervention) are made up, sent, received and processed.

An invoice in pdf format via e-mail is no longer valid from then on.

What is PEPPOL?

PEPPOL is a secure and standardized networkwhich is used to make these Exchange electronic invoices in a format defined by the EU. So PEPPOL is not a software, but a network. You do have compatible software needed to access this PEPPOL network. Use of this network provides, among other things:

• Reliable verification of senders and receivers
• Less chance of fraud (such as phantom invoices)
• Less chance of errors

All invoice data (supplier, customer, products, prices, VAT, etc.) are thus encrypted, along with a visible display of the invoice.

Also read: PEPPOL and e-invoicing: what does the new requirement mean for you?

Who is covered by the obligation?

• Belgian VAT-registered companies in B2B transactions -> also companies that were registered with VAT and opted for the 'small business exemption scheme'
• Foreign companies with a permanent establishment in Belgium.

What are the exceptions?

• Full of VAT exempt companies (art. 44 WBTW)
• Transactions with individuals
• Foreign companies without a permanent establishment in Belgium
• Lump-sum or bankrupt companies (limited)

So take note: if you mixed VAT are, which is usually the case, the obligation well.

How do I know if my company or a customer is covered by the obligation?

The most accurate and complete information on VAT schemes of both your own company and those of clients can be found at Intervat. This check is then best done twice:

1. Under which VAT regime Is my company registered with the VAT (under the exemption scheme or not)?
2. Is my customer registered with vat (individuals are never registered)?

From January 1, 2026, these checks will in principle be redundant. Considering your company and all VAT-registered customers by then must be effectively registered on the PEPPOL network.

Medical professions and e-invoicing concretely:

Sending sales invoices

Medical professions that Are completely exempt from VAT according to article 44 of the VAT Act (therapeutic activities only), fall not covered by the e-invoicing requirement For sending sales invoices.

Often, however, these occupations are mixed VAT and are registered for VAT purposes. In that case, the obligation well.

An example:

A dentist is exempt from VAT for his medical services with a therapeutic purpose. However, if he also offers aesthetic treatments (such as teeth whitening), then this dentist is a mixed VAT taxpayer and performs both operations exempt from VAT and subject to VAT. The dentist is then obliged to issue electronic invoices. This is also the case if the dentist has opted for the small business exemption scheme for his taxable activities.

Given that the customers/patients are mostly individuals, the obligation will only apply in a limited number of transactions. So when? For example, if the dentist wants to sell his car to a car dealer, he must send an invoice for it through the PEPPOL network. Likewise, if the dentist helps in a clinical study or writes an article for a professional journal, the obligation applies (assumption of VAT-paying transactions between VAT-paying companies).

Receiving purchase invoices

If you are registered for VAT, so too under the "small business scheme. Must be able to receive structured electronic invoices via PEPPOL.

So even if e-invoicing for the sales side would not apply for now, because there are never any outbound transactions covered by the obligation, it is thus necessary that you connect for the purchase side and therefore can receive electronic invoices.

What are the consequences if I don't comply?

As of Jan. 1, 2026, invoices in PDF, Word or Excel format are no longer valid for B2B transactions. This could lead to delay in the accounting or payment process, and perhaps to a discussion between the customer and the supplier.

In addition, you run the risk of a fine up to 5,000 euros (RD July 2025) for inability to receive or send electronic invoices.

Pro tip: join PEPPOL voluntarily and enjoy the benefits

Whether you are required to join or not, it is interesting to join the PEPPOL network. It is an opportunity to take advantage of the many benefits of electronic invoicing, such as:

• Faster processing and payment
• Better tracking and archiving of your invoices and possibly fees notes as well
• Fewer errors and less chance of fraud
• More efficient accounting

Also read: PEPPOL: obligation or opportunity?

Weather: the costs associated with billing packages (e.g. periodic subscription fees and consulting costs incurred specifically for the preparation and operationalization of e-invoicing) are tax deductible for 120% until assessment year 2029.

Conclusion

As of 2026, e-invoicing via PEPPOL mandatory for all VAT-registered B2B enterprises. Medical professions that are completely exempt from VAT are excluded from this requirement.

Often, however, these enterprises are mixed VAT and do fall under the e-invoicing obligation. Given e-invoicing brings many benefits, it is therefore a opportunity to join, even if it is not mandatory.