The impact of e-invoicing: are your terms and conditions already Peppol-proof?

Since Jan. 1, 2026 e-invoicing through the Peppol network mandatory for B2B transactions between Belgian companies subject to VAT. Perhaps you too have adapted your invoicing software by now and are sending your invoices correctly via the network.

But one aspect is often forgotten: updating your terms and conditions. In fact, the switch to Peppol is not just technical. It also haslegal consequences for how you bill, how invoice terms are enforceable and who is responsible for receiving invoices.

In this article, we explain why it's important to tailor your terms and conditions accordingly.

 

Peppol does not change basic rules around general terms and conditions

For the enforceability of general terms and conditions remain the same principles ago. Your customer must:

• receive them before or at the conclusion of the agreement;
• have had a real opportunity to read them
• Be able to accept them (explicitly or implicitly)

Many companies used to attach their terms and conditions to the invoice (e.g., on the back or as a PDF attachment). With Peppol, that works differently: invoices become automatic and structured exchanges between software systems.

Important: Receiving an invoice through Peppol does not automatically mean your customer agrees to the billing terms.

 

Why it's best to update your terms and conditions now

Mandatory e-invoicing through Peppol carries a number of practical risks if you don't adjust your terms.

 

1. Your terms are less visible

A Peppol invoice is aStructured digital document (UBL/XML). You can have a link or attach with your terms and conditions, but they are not always immediately visible to the recipient.

If a customer claims afterwards that he never saw your terms and conditions, it may problems give in discussions about payment deadlines or negligence interest, for example.

 

2. Invoices are processed automatically

Peppol invoices come directly into your client's accounting system. This may give the impression that an invoice is automatically accepted.

In reality, this is not legally true. Moreover, Peppol itself providesno built-in system to dispute invoices. That still happens off the platform.

Therefore, it is important that youmakes clear arrangements regarding the procedure for checking and disputing invoices.

 

3. Uncertainty about responsibility

E-invoicing involves two parties:

• the sender, which must send the invoice correctly through Peppol
• the recipient, which must be technically capable of receiving them

For example, if a customeris not properly registered on the Peppol network, this can generate discussions about whether the invoice was sent in a legally valid manner.

That, too, is best laid out in contract.

 

 

How do you make your terms and conditions Peppol-proof?

1. Invoicing through Peppol & recipient responsibility.

Record that invoicesbe sent electronically via Peppoland in that way are legally valid.

Also include that your clientitself is responsible for active Peppol registrationand proper receipt of invoices. This way you avoid discussions when a customer does not have a working Peppol ID, for example.

 

Sample clause - e-invoicing via Peppol (sender):

'The Seller sends invoices electronically via the Peppol network in accordance with EN 16931. The Buyer undertakes to receive and process these invoices in that format.'

 

2. Fraud Alert

Peppol increases the safety of billing significantly. The network works with controlled access points and unique identifiers.

But it is no foolproof system. Therefore, it is wise to have a disclaimer around fraud and controls to include.

 

Sample clause - risk mitigation/fraud warning:

'While Peppol reduces the likelihood of error and fraud, it does not provide an absolute guarantee. The Customer remains responsible for internal controls, including verification of vendor data, Peppol IDs and approval procedures.'

 

Also don't forget these elements

Agreements around acceptance and contestation

Record clearly within which time period an invoice must be disputed and in what waythis should be done (e.g., in writing).

This remains crucial because Peppol itself does not provide a contestation procedure.

 

Payment terms and penalties

Make sure youpayment terms aligned with electronic billing, for example:

• payment terms
• negligence interest
• damages for late payment

 

 

Conclusion: Peppol is also a legal story

Many entrepreneurs focus mainly on software and technical implementation at Peppol. But the switch has alsocontractual consequences.

By updating your terms and conditions:

• avoid discussions about the validity of invoices
• Strengthen your position in case of default
• and create clarity for your customers

In short: e-invoicing via Peppol also requires Peppol-proof terms and conditions.