What is new in Belgium?
March 31st 2022 a new Royal Decree has been published, mandating B2G invoicing also for the suppliers.
This mandate will be phased where at first large contracts (September 2022), then medium size (March, 2023) and finally also the small contracts (September, 2023) need to comply.
We already had mandated e-Invoicing for the Flemish region, so now this mandate is expanded to all public entities, counting approximatively 5.000 in total.
What is a public entity?
Whenever an organisation needs to comply to public tenders, as they are operating primarily on public funds, they are categorized as public entity.
Peppol connection to Mercurius is needed
The setup remains the same: invoices need to be exchanges using the Peppol network and need to comply to EN-16931 UBL. BoSa (the IT services agency and local Peppol Authority) hosts a Peppol Access Point infrastructure, commonly known as ‘Mercurius’, from which they distribute documents to all final recipients.
In Belgium the preferred addressing scheme to be used is the CBE (cross-points bank of enterprises) registration of the entities involved. There are a few exceptions however, where GLN or VAT registration is to be used.
The CBE is 10 digits long, starting with 0 or 1 (yes, this is new). Do not mistake this with VAT registration number, as most often but not always this is the same as the CBE preceded with ‘BE’.
For the Flemish government, the purchase order reference is also used as a routing mechanism to identify the targeted administration when multiple exist within a single legal identity.
What about Hermes then?
Within the scope of the Hermes initiative of BoSa, every business or entity established in Belgium is registered using the CBE registration number in a separate address book (SMP). To be able to deliver invoices to participants registered within Hermes, a supplier or his Peppol service provider needs to sign-up with with BoSa. Invoices delivered on the Hermes platform are forwarded by e-mail to the recipient. So, also the e-mail address of the buyer needs to be included in the invoice.
Currently some public entities have no Mercurius registration and are discoverable only through Hermes. Without the contract with BoSa, those documents will not be processed. These entities will need to be moved to Mercurius (the ‘open’ address book for Peppol participants) or another SMP hosted by another Peppol service provider.
Belgium was one of the first regions with systematic use of status message feedback (MLR) as a positive or negative receipt. Responses with the invoice status will be supported.
For these responses to be exchange, the supplier needs to be registered for reception of these messages. ViaAdValvas customers have this included in the setup.