Duration: 33:15
🧾 Analytical Summary
📋 Context & Mandate
Serge Liber, project manager for e-invoicing at Belgium's Federal Public Service BOSA (Policy and Support), delivers a comprehensive technical briefing on Belgium's ambitious e-invoicing mandate. The presentation targets IT solution providers like Odoo, addressing the infrastructure, standards, and timeline requirements for the January 1, 2026 deadline when all VAT-liable entities in Belgium must send and receive structured electronic invoices.
BOSA serves as the federal agency responsible for digitalization and simplification across government services. Liber has managed e-invoicing projects since 2013, bringing both private sector experience (IBM, Citibank, KPN) and over two decades of public sector expertise to the role. Belgium has designated BOSA as the official Peppol Authority for the country—a critical governance position in the decentralized e-invoicing ecosystem.
The scale of the undertaking is substantial: Belgium has 1.2 million VAT-liable entities among approximately 2 million total enterprises, generating an estimated 1 billion invoices annually—of which 400 million are B2B transactions that will fall under the mandate.
🌍 Why E-Invoicing Matters
Liber frames e-invoicing as far more than digitizing paper documents. The invoice connects to virtually every critical business process: sales cycles, accounting, cash flow management, VAT collection, procurement, banking relationships, and legal documentation. Digitalizing invoicing creates spillover effects across the entire economy, making it a powerful lever for comprehensive digital transformation—especially for SMBs that lack the resources larger enterprises dedicate to digitalization.
Belgium's approach reflects this holistic view. E-invoicing isn't merely a tax compliance exercise; it's infrastructure investment enabling automation, interoperability, and innovation across economic sectors. The government's role is not to provide solutions but to establish standards and governance ensuring the market can deliver solutions that work seamlessly together.
📜 The Legal Framework
Belgian law (enacted February 6, 2024) mandates that all VAT-liable entities must send and receive structured electronic invoices by January 1, 2026. The legislation establishes a two-track system:
Track 1: The Royal Way (Peppol): This is the standard, guaranteed-to-work solution. Any company can achieve compliance by ensuring they can send and receive invoices via the Peppol network using the European standard format. Paper + Peppol compliance is the "common denominator" that ensures universal interoperability.
Track 2: Bilateral Agreements: If sender and receiver both agree on an alternative method (e.g., proprietary EDI networks), they may use it "at their own risk and peril." However, both parties must still maintain Peppol capability as fallback since not all trading partners will use the same alternative networks.
This two-track approach balances standardization with flexibility while ensuring no company gets locked out of the economy for lacking access to proprietary networks.
🔗 Understanding Peppol
Many attendees likely wonder: what exactly is Peppol? Liber offers a simple analogy: imagine you have software and want to send invoices to partners without knowing what software they use. You need a "cable" that connects your system to theirs and ensures both sides understand not just the file format but the actual content. Peppol is that cable—a standardized network enabling any sender to reach any receiver.
Technically, Peppol is a decentralized, federated network based on open standards with strong governance. The architecture consists of four layers:
Outer Periphery: All the businesses and entities exchanging invoices—the beneficiaries of the network.
Inner Periphery: The Access Points (operators)—currently over 800 globally and 90+ active in Belgium. These are IT companies (including Odoo) that provide the technical infrastructure connecting users to the network. This layer enables infinite scalability since no single operator becomes a bottleneck.
Outer Center: The Peppol Authorities—decentralized governance bodies in each participating country. BOSA serves this role for Belgium. Authorities enforce standards, certify operators, and ensure compliance with interoperability rules.
Inner Center: The coordination bodies—centralized entities that cannot be decentralized without breaking the network. This includes the Peppol Coordinating Authority (PCA), Service Metadata Locator (SML), and various boards managing changes, operations, and strategic decisions.
This layered architecture enables global interoperability at massive scale while maintaining security, reliability, and governance.
📨 How Invoice Exchange Works
When a sender creates an invoice, their Access Point component queries the Service Metadata Publisher (SMP) to discover the receiver's Access Point address and capabilities. The Service Metadata Locator (SML) directs the query to the correct SMP (since these are decentralized by country). Once the sender's Access Point obtains the receiver's Access Point details, it transmits the invoice directly between Access Points, which then deliver it to the receiver's inbound invoicing tool.
This "lookup-then-send" model enables any sender to reach any receiver globally without pre-configured connections—true plug-and-play interoperability.
📊 Adoption Progress
Belgium's rollout is progressing but faces significant acceleration requirements. As of the presentation:
- 413,000 receivers registered on Peppol (target: 1.2 million)
- 1.6 million Belgian Peppol invoices monthly (July 2024), up from 600,000 earlier in the year
- Belgium ranks #2 globally for Peppol invoices per capita (behind Norway, which started 10+ years earlier)
- 90+ Access Point operators certified in Belgium, growing rapidly
Liber displays a "hockey stick" growth curve needed to meet the 2026 mandate—ambitious but achievable given accelerating operator adoption and business awareness.
🛡️ Governance & Contracts
Peppol's reliability stems from its contractual chain. Each Access Point operator signs agreements with Peppol Authorities, which have agreements with the central Peppol Coordinating Authority. Both sender and receiver have contracts with their respective Access Points. This federated trust chain ensures consistent terms and conditions across the network, enabling juridical safety and operational reliability despite decentralization.
Standards are carefully managed through Change Management Boards to prevent interoperability breaks when upgrades occur—a critical function given continuous evolution across 800+ operators globally.
🌐 International Expansion
Peppol began as a European initiative but has expanded globally. Japan, New Zealand, Australia, and Malaysia have adopted the framework, with more countries joining. Belgium's decision to standardize on Peppol positions Belgian companies for seamless international trade as the network becomes truly global.
A major innovation on the horizon: the Peppol International Invoice Model. Currently, European and Asia-Pacific regions use slightly different standards (particularly around tax handling), creating friction in inter-regional exchanges. The new model establishes a "core overlap" where regional standards share essential elements while retaining regional specificity. This enables cross-regional invoicing without requiring identical standards—a breakthrough for global interoperability.
⚙️ Practical Considerations
What if suppliers aren't ready by January 1, 2026? It's not the sender's problem if the receiver isn't Peppol-capable. Senders remain compliant by attempting Peppol delivery, then using cascading fallback methods (typically PDF via email). Liber recommends including disclaimers on PDF invoices directing receivers to resources for getting Peppol-ready—turning compliance into an opportunity to help trading partners digitalize.
Are Peppol services free? There's no fee from the Belgian Peppol Authority (funded by public money), but Access Point operators charge for their services as part of software offerings (like Odoo's integrated solution). Central coordination bodies are funded through membership fees from operators and authorities.
What about private individuals? The mandate applies only to B2B (business-to-business) invoices between VAT-liable entities. B2C (business-to-consumer) invoices remain outside the scope for now, though this may evolve as automation tools become available for household invoice management.
Security concerns? Peppol's decentralized architecture is a security feature—if one operator is compromised, only a small fraction of the network is affected. Operators face strict obligations for end-user identification and security. Liber notes that in over 10 years, major security incidents have been negligible.
What about France and other countries? France is implementing its own e-invoicing system but also maintains a French Peppol Authority, and cross-border interoperability between Belgian and French systems is expected. The presenter awaits details but expresses confidence in cross-border functionality.
💬 Key Insights
E-invoicing is not merely a compliance checkbox—it's economic infrastructure comparable to highways or telecommunications networks. Getting this right unlocks productivity gains, fraud reduction, faster payments, and competitive advantage for businesses that embrace it early.
The market-based approach distinguishes Belgium's strategy. Government sets standards and provides governance but doesn't operate the infrastructure. This fosters innovation, competition, and diversity of solutions while ensuring interoperability through open standards.
The cascade approach to compliance (try Peppol first, fall back to alternatives if needed) balances pragmatism with standardization. Businesses should build their systems to attempt structured e-invoicing, then gracefully degrade to PDF or other methods when counterparties aren't ready—while encouraging adoption through education and tooling recommendations.
Transversal thinking is essential. E-invoicing touches finance, IT, procurement, legal, and regional competencies. Success requires breaking silos and coordinating across disciplines—a challenge Belgium's complex federal structure (Flemish and Francophone regions, multiple oversight bodies) knows intimately.
🧠 Viewpoint: Odoo Perspective
⚠️ Disclaimer: AI-generated creative perspective inspired by Odoo's vision.
Liber's presentation crystallizes why we've invested deeply in Peppol integration from day one. E-invoicing mandates create a rare opportunity: regulation that genuinely levels the playing field by requiring interoperability. Suddenly, small businesses using Odoo can exchange invoices as seamlessly as multinationals with dedicated EDI teams—if the infrastructure is built correctly.
What excites us about the Belgian approach is the emphasis on open standards and market-driven solutions rather than government-operated platforms. This creates space for innovation while ensuring no vendor can lock customers into proprietary ecosystems. When BOSA certifies 90+ Access Point operators, they're saying: competition on features, reliability, and service quality—not on artificial network effects or closed standards. This is how digital transformation should work: government sets fair rules, private sector delivers solutions, and customers choose what works best for their needs. Odoo's role is making Peppol compliance so seamlessly integrated that customers don't think about e-invoicing as a separate project—it's just how invoices work, automatically, from day one.
🏢 Viewpoint: Competitors (SAP / Microsoft / Others)
⚠️ Disclaimer: AI-generated fictional commentary. Not an official corporate statement.
Belgium's Peppol mandate highlights the increasing complexity of regulatory compliance across European jurisdictions. While Liber positions this as an opportunity for SMB digitalization, large enterprises must navigate a patchwork of national e-invoicing requirements—Belgium's Peppol approach, France's hybrid system, Italy's SDI model, Germany's emerging framework—each with different timelines, standards, and governance structures.
The "cascade approach" (try Peppol, fall back to PDF) is pragmatic but underscores transition challenges. Enterprises with thousands of suppliers across dozens of countries need sophisticated exception handling, audit trails, and reconciliation logic when trading partners operate at different adoption speeds. The Access Point operator ecosystem—while fostering competition—also creates integration complexity when customers use multiple ERP systems and need to consolidate reporting across different operators.
That said, the move toward structured data and standardized formats is unambiguously positive. EDI's proprietary nature has locked small businesses out of automated invoicing for decades. Peppol's open standards finally democratize access—though enterprise-grade implementations still require handling legacy EDI alongside Peppol during extended transition periods. The real test will be whether cross-border interoperability delivers on its promise as countries adopt incompatible national variations of ostensibly standard frameworks. Belgium's pragmatic, market-driven approach sets a constructive example, even if execution complexity remains substantial.
Disclaimer: This article contains AI-generated summaries and fictionalized commentaries for illustrative purposes. Viewpoints labeled as "Odoo Perspective" or "Competitors" are simulated and do not represent any real statements or positions. All product names and trademarks belong to their respective owners.