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Digital invoicing in co-ownership management

As of January 1, 2026, Belgium implements a general e-invoicing requirement for B2B transactions. This means Belgian companies with a valid VAT number must now exchange structured electronic invoices via the European Peppol network(Peppol website). In practice, you can no longer send an invoice as a PDF by e-mail; a Peppol-certified invoice in the standard Peppol BIS format is the new norm(Belgisch Staatsblad 20/02/2024). This obligation stems from the law of February 6, 2024 which amended the VAT Code to mandate e-invoicing(Wet van 6 februari 2024).

Crucially, this requirement only applies to VAT-registered businesses trading with each other(FOD Financiën e-facturatie). In short: invoices between two Belgian VAT-registered companies must go through Peppol, but if one party does not have a VAT number, the obligation disappears(FOD Financiën uitzonderingen). The legislator’s goal is to protect VAT revenues and combat fraud, so the new rules only kick in between entities that file VAT returns(FOD Financiën toelichting).

Who falls under the e-invoicing obligation?

• B2B transactions between two VAT-registered businesses: fully mandatory from 2026 via Peppol(Peppol network).
• Exceptions: bankrupt companies, only VAT-exempt activities (art. 44 VAT Code), foreign VAT-registered entities without a Belgian PE-establishment, flat-rate VAT schemes until 2028(FOD uitzonderingen).
• If one party has no VAT number: no Peppol invoicing requirement(FOD uitzonderingen). Typically this means invoices to/from private individuals or non-VAT entities are exempt.

Concretely: imagine you, as a (voluntary) property manager, issue an invoice to the owners’ association (VME) or vice versa. Both parties are usually not VAT-registered (see below). According to official guidance, the obligation then does not apply because one party lacks a VAT number(FOD Financiën FAQ). You remain free to invoice by paper or e-mail as before.

Impact on co-ownership managers

This rule is favorable for both non-professional and professional property managers:

• Voluntary managers (private individuals): they typically aren’t VAT-registered. They manage property without profit motive and rarely issue invoices—in most cases they collect only advances and settle accounts. Since they lack a VAT number, their inter-resident invoicing isn’t subject to Peppol rules(FOD uitzonderingen). The new requirement changes nothing for them; they can continue as usual.
• Owners’ associations (VME): although a VME is a legal entity with an enterprise number (Burgerlijk Wetboek artikel 577-5), it solely performs management tasks. Legal scholarship confirms a VME is not considered a VAT-registered business unless it conducts other economic activities(BW art. 577-5 toelichting). In practice, a VME receives invoices for maintenance or utilities and passes them on without mark-up. Thus, a VME generally neither issues nor receives VAT invoices, and is exempt from the Peppol obligation.
• Professional managers (VAT-registered firms): they hold VAT numbers because they charge fees. If they invoice other VAT-registered businesses (e.g. a corporate co-owner), those invoices must be sent via Peppol after 2026. However, they typically invoice the VME or individual residents—since a VME normally lacks VAT registration, no Peppol obligation applies(FOD Financiën FAQ). Therefore, professional managers can continue using traditional invoices within a co-ownership context. Only for invoices to other B2B clients outside the co-ownership will they need to switch to e-invoicing via Peppol.

In short: day-to-day operations for most co-ownership managers remain virtually unchanged. If you (or your manager) already use digital accounting, integrating with Peppol will be straightforward. For in-building transactions, no immediate change is required. Rest easy: the new law targets large-scale B2B billing, not your co-ownership office.

Civil Code provisions on co-ownership

The rules for co-ownership and managers appear in the Civil Code. For example, Burgerlijk Wetboek artikel 577-5 establishes that upon formation of a co-ownership, an “owners’ association” is automatically created to manage the building(BW art. 577-5). That VME receives an enterprise number and must display it on its documents(BW art. 577-5). Under artikel 577-9 BW, the VME has legal standing to sue or be sued(BW art. 577-9). These provisions show a VME is an organizational entity solely serving building management, not commercial profit. The Civil Code governs its structure and duties but says nothing about invoicing formats. In the context of e-invoices, the key point is that—even with an enterprise number—a VME usually is not a VAT-registered business. Hence, the 2026 VAT law does not apply to it.

Similar rules in other countries

Belgium is not alone: EU Directive 2018/2080 paves the way for mandatory e-invoicing. Many member states have already or will soon implement requirements. For instance, in France, e-invoicing for B2B became mandatory in 2024, following earlier B2G requirements(EU Directive 2018/2080). Italy has operated a national SDI system for mandatory electronic invoicing since 2019(Italy SDI). Spain and Sweden are likewise planning or implementing B2B e-invoicing. In the Benelux, the Netherlands and Luxembourg actively adopt Peppol to meet these mandates(Peppol in Benelux). Overall, Peppol serves as a common standard across these countries. For Belgian real estate, this convergence has minimal effect: the VAT Code’s article 44 exemption and the “private or VME” scenario remain decisive.

Conclusion: no need to panic

For property managers, the rollout of Peppol-based invoicing in 2026 will not upend standard practices. Voluntary (non-professional) managers and regular VMEs operate outside VAT registration and need not worry about Peppol technicalities(FOD Financiën FAQ). Professional managers will continue their current invoicing for co-ownership transactions; only invoices to other VAT-registered businesses require transition to e-invoicing (and there is ample lead time). In sum, the new law targets large-scale B2B dealings, not your co-ownership workflow. You can confidently continue your customary management practices.

Sources: VAT Code (law of February 6, 2024)(Wet van 6 februari 2024); Civil Code articles on co-ownership (art. 577-5 and 577-9 BW)(BW art. 577-5), (BW art. 577-9); official FOD Financiën guidance on e-invoicing(FOD Financiën e-facturatie); EU Directive 2018/2080(EU 2018/2080).