# Belgium after go-live: self-billing and unready recipients After go-live, the difficult invoices are often the exceptions: a customer cannot receive, a supplier sends an unexpected PDF, or a buyer-issued invoice has no clear approval owner. These need a documented decision and a path back to ordinary operation. Leaving every difficult item on the workaround introduced in January is not a sustainable process. Use the [Belgian exception worksheet](#template) to record the applicable guidance, attempted delivery, temporary route and final reconciliation. The process below distinguishes actual authority guidance from recommended controls. ## Reconfirm scope before classifying a delivery failure Belgium's authority states that the relevant domestic B2B structured-invoicing requirement applies from **1 January 2026**; an emailed PDF alone is not the ordinary structured-invoice solution. Tax must assess the actual entities, establishment, transaction and exclusions, rather than equating a failed network lookup with a legal exemption. [Belgian authority: structured invoices since 2026](https://einvoice.belgium.be/en/article/structured-electronic-invoices-between-companies-are-compulsory-2026). For each exception, record who supplied what to whom and which party issues the invoice. Check legal identity and tax facts before changing the route. A consumer, foreign counterparty and domestic business need not have the same obligation, even when the software reports the same technical error. Save the scope conclusion and its reviewer. If the facts are unclear, assign a tax question and an operational owner. Do not clear the queue by marking a customer "out of scope" solely because its endpoint cannot be found. ## Retire expired tolerance assumptions The authority's general tolerance concerned the **first three months of 2026**, subject to timely and reasonable compliance efforts. It explicitly was not a general postponement. That period is historical on 17 October. [Belgian authority: first-quarter tolerance](https://einvoice.belgium.be/en/news/period-tolerance-during-first-three-months-2026). The general FAQ separately described conditional self-billing flexibility **until 30 June 2026**. That date is also past. Keep the source and period in the exception history, but do not cite it as current blanket permission for an unsupported self-billing product. [Belgian authority: general FAQ, question 23](https://einvoice.belgium.be/en/FAQ/general-questions-b2b). Review workaround rules created during those periods. For each, either establish a current basis, migrate to the supported normal process or escalate the unresolved case. A provider's old implementation promise does not extend an administrative tolerance period. ## Investigate the recipient before choosing an alternative Validate the intended business identity, identifier scheme and actual discovery result through the supported provider process. Check whether the issue is absence, a wrong identifier, an unavailable endpoint or an unsupported document/process. Retain the diagnostic result and time checked. Ask the recipient to confirm its receiving arrangement and involve the providers when necessary. Contact details should come from verified business records. A request to send invoices to a new address can also be a routing or fraud risk and deserves the usual verification. The current FAQ states that an unready customer can be sent an invoice by an agreed secure alternative; electronic alternatives require the customer's agreement. It also says the sender should not later resend those invoices as structured documents merely because the customer becomes operational. Preserve the particular exception evidence and agreement rather than treating this as a substitute for normal readiness. [General FAQ: unready customer, question 8](https://einvoice.belgium.be/en/FAQ/general-questions-b2b). Give the alternative route an owner and a review date. Mark the original document as exceptionally delivered with evidence, not indefinitely waiting for a normal transmission that someone will later replay without context. ## Keep self-billing roles clear The FAQ permits self-billing with a prior agreement and an acceptance procedure for each invoice by the supplier making the supply. Network transmission does not replace that business approval. [General FAQ: self-billing, question 10](https://einvoice.belgium.be/en/FAQ/general-questions-b2b). Document which party creates the invoice, whose sale it represents, how the supplier accepts or disputes it and who produces corrections. Preserve true seller and buyer identities even when the buyer's system generates the file. Set separate operator roles for preparing a self-bill and approving its commercial contents. Ask both providers to demonstrate the actual supported self-billing process and document family. Test receipt, rendering, source identity, acceptance and correction. Do not infer support from a successful ordinary invoice test or from a field labelled "self-billing" in an ERP. If a party also issues an ordinary invoice for the same supply, investigate before posting. The controlling agreement and actual documents determine the resolution. Automatic matching by amount can hide a duplicated liability or sale. ## Work through an unready customer Assume Belgique Exemple has confirmed that a domestic B2B sale is in scope. The approved supply is **EUR 1,000 net plus illustrative 21% VAT**, total **EUR 1,210**. The customer identity is correct, but the supported discovery/delivery process establishes that it cannot currently receive the invoice. These are synthetic test facts, not a finding about a real business. AR records the failed normal-route evidence, confirms the facts with the customer and obtains agreement to a secure electronic alternative under the current FAQ scenario. It sends invoice BE-100 once through that agreed route and stores delivery evidence. The receivable remains one EUR 1,210 sale, with an exception status identifying why the ordinary route was not used. Later, the customer connects. AR updates the prospective routing record and tests the next invoice. It does not replay BE-100 automatically through the structured route merely to make a historic dashboard show network delivery. The exception record explains why BE-100 and later invoices have different delivery evidence. If no secure alternative is agreed or identity remains uncertain, keep the case open with tax/commercial escalation. This example does not promise that every failed transmission qualifies for the same fallback. ## Work through a self-billed supply In a separate scenario, assume a buyer and supplier have the required agreement and acceptance procedure. The buyer prepares SB-100 for **EUR 500 net plus illustrative EUR 105 VAT**, total **EUR 605**. The supplier checks that the underlying supply occurred and accepts through the agreed process. Both parties retain the structured document and acceptance evidence linked to the same supply. An approved reduction is then **EUR 50 net plus EUR 10.50 VAT**, total **EUR 60.50**. The expected remaining commercial position is **EUR 544.50**. The test must use the agreed, supported correction process and preserve the original relationship; it must not silently replace SB-100 with a new EUR 544.50 file. Test supplier rejection separately. A technically delivered self-bill is not proof that the supplier accepted the commercial contents. The operator should see the dispute and know which party can resolve or correct it. Reconcile both parties' records where the agreed process requires coordination. ## Retain evidence and recover safely Keep original structured content, attachments, delivery/response evidence, agreement and approval references. Confirm that the archive can render the document and export it with its relationships. Retention and other applicable record obligations need their own approved schedule. For an unknown outcome after a timeout, query the existing attempt through the provider's supported process before sending again. Distinguish a confirmed rejection from silence. Do not issue another invoice number as the first recovery step. Review exceptions by cause and age. Endpoint errors belong to the routing/provider owner, party identity to master data, tax scope to tax and self-bill disputes to the commercial approval owner. The controller should reconcile ordinary, exceptional and self-billed populations without treating them as three separate sales ledgers. ## Ready checklist - ☐ The actual taxpayer/transaction scope is approved. - ☐ First-quarter and June self-billing tolerances are treated as expired historical periods. - ☐ Failed discovery/delivery has diagnostic evidence and a named owner. - ☐ Any alternative route has the applicable basis and secure agreement. - ☐ Historic fallback invoices are protected from automatic later replay. - ☐ Self-billing agreements, supplier acceptance and corrections are tested. - ☐ Duplicate ordinary/self-billed documents do not create extra balances. - ☐ Originals, responses and approval evidence can be retrieved. - ☐ The controller reconciles amounts and closes or escalates every exception. Use [Peppol process checks](https://erplocalization.com/guides/peppol-tax-compliance-checklist/) for discovery evidence and [provider replacement](https://erplocalization.com/guides/choose-and-replace-e-invoicing-provider/) when gaps require a service change. ## Worksheet: Belgian e-invoice exception worksheet Copy this worksheet for each case. It records decisions and evidence; it does not determine the tax or legal treatment. Show the worksheet Use with [the Belgium guide](https://erplocalization.com/guides/belgium-e-invoicing-exceptions-after-go-live/). Repeat per exception; blanks are intended inputs. ### Scope and trigger - Issuer, supplier, buyer and transaction: - Taxpayer/transaction scope decision and reviewer: - Discovery/delivery result, identifier and timestamp: - Technical cause and provider confirmation: - Authority basis, effective dates and expired-period check: ### Resolution - Ordinary route / agreed secure alternative / self-billing review / unresolved: - Customer agreement and verified delivery details: - Original invoice, amount and delivery evidence: - Protection against retrospective replay/duplicates: - Self-billing agreement and supplier acceptance, where relevant: - Correction responsibility, original reference and actual outcome: - Owner, review date and escalation: ### Acceptance - Synthetic BE-100: one EUR 1,210 sale despite different delivery evidence: - Synthetic SB-100: EUR 605 less EUR 60.50 approved reduction = EUR 544.50: - Ordinary/self-billed duplicate check: - Unknown-outcome recovery test: - Archive retrieval and reconciliation evidence: - Controller approval and remaining conditions: **Sources checked:** 17 October 2026. The fallback described is the authority FAQ's unready-customer scenario; apply it to matching facts and retain the decision. This guide does not extend expired tolerance periods or claim automatic self-billing support in any ERP. ## Related on this site - [Country pages](https://erplocalization.com/countries/): key facts with sources - [E-invoicing matrix](https://erplocalization.com/e-invoicing/): country × ERP support - [All guides](https://erplocalization.com/guides/) Vendor documentation is cited only as an example of the level of evidence to ask for; it is not a recommendation or a ranking. This guide is general information, not tax or legal advice. Checked 2026-10-17. Related: [Glossary](https://erplocalization.com/glossary/) – abbreviations and terms used in these guides (SAF-T, Peppol, CTC, EN 16931, IFRS and more). --- Canonical: https://erplocalization.com/guides/belgium-e-invoicing-exceptions-after-go-live/ · Last updated: 2026-10-17 · Informational only; not tax, legal or implementation advice. Featured placements are paid or promotional and do not affect the compliance data. Data: CC BY-NC 4.0 (commercial use needs a licence: https://erplocalization.com/data-licence/), attribution "ERP Localization (erplocalization.com)".