Peppol invoicing from 2026: Why your general terms and conditions require attention now

The problem: general terms and conditions and peppol do not automatically fit together

Until now, many companies have attached their general terms and conditions to invoices: printed on the back of a paper invoice or as a PDF attachment to an email. This method is familiar and works well.

With Peppol, things are different. Invoices are no longer PDFs, but structured digital files with fixed fields for specific information.

The Peppol system allows attachments to be sent (including in PDF format), but there is no guarantee that the recipient will receive or process them correctly. Whether your customer sees your general terms and conditions depends on the software they use. An incorrect mention may mean that your general terms and conditions are not visible or not noticed.

The Risks: what is at stake?

If your general terms and conditions are not communicated correctly, you face concrete risks:

1. Lack of proof of notification and/or acceptance: Your customer may dispute that they knew or accepted your general terms and conditions. Your terms may then not be legally enforceable.
2. Weakened legal position in case of non-payment: Provisions regarding payment terms, penalty clauses, and interest are no longer enforceable in case of non-payment, with all the consequences that entails.

The Solution: communicate general terms and conditions fefore the invoice

The best way to avoid risks is simple: ensure your customer knows and accepts your general terms and conditions before you send the invoice via Peppol.

Why general terms and conditions attached to the invoice (only) are not sufficient
An invoice often comes after the agreement has been concluded. The risk is therefore real that your customer rejects the acceptance of your general terms and conditions, especially in one-off transactions, because they were not aware of these terms when the agreement was made. Also, if the invoice remains unpaid by the customer, there is no acceptance of the general terms and conditions with the invoice.

Conclusion: Share Your General Terms and Conditions Preferably with Quotations, Order Forms, and Collaboration Agreements
Referring to terms and conditions on the invoice can serve as extra confirmation, but not as the only method.

Practical tips for “Peppol-Proof” general terms and conditions

1. Share general terms and conditions (as PDF attachment) with the quotation or order form and not only with the invoice
   This way, (in theory) there can be no discussion about the correct notification of the general terms and conditions.
2. Discuss technical implementation with your accountant / software provider
   With Peppol, it is very important to provide the correct information in the correct field.
   Discuss with your accountant or invoicing software provider which fields and information elements you will use. In the correct fields of an electronic invoice (UBL XML file), a link to the general terms and conditions or even an embedded PDF document can be included. Make sure the implementation in your software is correct and that you use the right fields and formats, so your general terms and conditions arrive correctly with the recipient.
3. Adjust general terms and conditions for E-invoicing
   It is important to review your general terms and conditions and B2B agreements with Belgian VAT-liable parties and include clear clauses about e-invoicing via Peppol.
   Include a clause in your general terms and conditions stating that invoices are only legally valid once they have been exchanged via Peppol.
4. Contractually establish responsibilities
   It is strongly recommended to contractually establish what the consequences are if one of the parties does not comply with their Peppol obligations. Clear agreements about liability help to avoid discussions and disputes in the future.
5. Refer to your general terms and conditions on the invoice
   The invoice can also state that “the general terms and conditions apply as provided on the quotation or order form”, with or without a hyperlink to the general terms and conditions. In Peppol, this can also be mentioned in the free text field that is sent in the structured file.

Action Plan: What Should You Do Now?

The deadline of 1 January 2026 is approaching quickly. To be ready in time, we recommend following these steps:

Step 1: Review your current processes (by the end of 2025)
Step 2: Consult with your accountant and software provider (autumn 2025)
Step 3: Adjust your general terms and conditions (by the end of 2025)
Step 4: Implement the new working method (from early 2026)

Start preparing today, so you can make the transition to Peppol with peace of mind on 1 January 2026.

PKF BOFIDI and PKF BOFIDI Legal Law Firm are happy to assist you with this.
Contact pieter-jan.vanmierlo@pkfbofidilegal.com or e-invoicing@pkfbofidi.com for support.

This article was written by Pieter-Jan Van Mierlo.