Medical care is exempt. Expertise is not.

Therapeutic services are exempt from VAT (article 44, §1 of the Belgian VAT Code): consultations, care, preventive acts. A doctor who only invoices patients therefore has no Peppol issuance obligation.

Medical expertise is in a different position. Missions to assess personal injury, insurer mandates, court-appointed expertise, corporate missions, have no therapeutic purpose: they are subject to VAT. As soon as they are invoiced to a VAT-registered Belgian business (an insurer, a law firm, a company), they fall within the scope of the Peppol obligation as of 1 January 2026.

Receiving invoices is also in scope

Every practitioner with a VAT number, even under the small-business regime, must be able to receive structured electronic invoices. Your suppliers are gradually moving to Peppol; a mailbox is no longer enough.

The tolerance period is over

The tax authority applied a three-month tolerance in early 2026 to give businesses time to get equipped. We are now in July: that window has closed. An expert practice still invoicing its insurer mandates as PDFs by email exposes itself to rejected invoices, and eventually to penalties.

Three ways to become compliant

  1. Go through your accounting software or a third-party provider. It works, but adds re-entry: file data (parties, services, fees) must be re-encoded in the invoicing tool.
  2. Use a generic Peppol platform. Same problem, plus one more subscription.
  3. Invoice from the tool that already holds the file. That is the choice of Medicalex: IT Place operates its own Peppol Access Point (AP/SMP). The invoice is generated in UBL 2.1 format directly from the closed expert file, fees calculated, data pre-filled, and transmitted without intermediary, with real-time acknowledgement. The module is available as an option on every plan.