Annual VAT client listing: a new obligation for small businesses from 2026

Starting this year, an important, yet relatively unnoticed, obligation applies to certain small businesses in Belgium.

Here is the English version, clear and professional 👇

Businesses operating under the VAT exemption scheme must now submit an annual client listing, even if no goods or services were supplied.

🔍 A little-known change

Until now, businesses under the VAT exemption scheme (often small companies or self-employed individuals) were exempt from several VAT obligations, including the submission of the annual client listing when it was nil.

This is no longer the case as of 2026.

From now on, they must submit this listing to the tax authorities, even if no transactions have taken place.

A deadline not to be missed

The first deadline is set for:

March 31, 2026

The listing must include VAT-registered clients to whom services were invoiced during the previous year (2025).

What is the annual VAT client listing?

The annual VAT listing is a report that includes:

• Belgian VAT-registered clients
• the total amount of transactions carried out with each of them
• their VAT number

This obligation aims to improve transparency and tax control.

No need to worry: your accountant will handle it

In most cases, your accountant will take care of this obligation on your behalf.

This requirement is a natural part of the annual follow-up of your file.

Who is concerned?

This applies to:

• businesses under the VAT exemption scheme
• that have carried out transactions with VAT-registered clients in Belgium

A reform aligned with digitalization

This measure is part of a broader trend:

• strengthened VAT control
• digitalization of tax obligations
• preparation for the PEPPOL ecosystem and mandatory e-invoicing from 2026