10-Year Document Retention: Meeting Belgian Compliance Requirements

Belgian Retention Requirements

Belgian law requires businesses to retain accounting documents, including invoices, for a minimum of 10 years. This is not a suggestion; it is a strict legal obligation.

The Legal Framework

The obligation is rooted in several texts:

Code of Economic Law (CEL), Book III, Title 3, Chapter 2: Requires enterprises to keep books and accounting documents for 10 years (previously 7 years, extended in recent years).

VAT Code, Article 60: Explicitly mandates the retention of invoices for VAT control purposes.

Calculation of the Period

The 10-year period starts from the 1st of January of the year following the tax year. Example: An invoice dated 15 March 2024 must be kept until 31 December 2034.

---

Paper vs. Digital: Legal Equivalence

Belgium fully accepts digital archives as equivalent to paper, provided certain conditions are met (Circular 2020/C/20).

Can I throw away the paper?

If you receive a paper invoice and digitize it ("dematerialization"), you can destroy the paper original ONLY IF your digital scanning process guarantees complete fidelity and integrity. For born-digital (Peppol) invoices, the XML is the original; printing it has no legal value.

---

Data Migration Strategy

A common compliance pitfall occurs when switching software providers.

The "Lock-In" Risk: If you switch ERPs in 2028, what happens to your 2024 invoices?

1 Export Format: Ensure your archive supports bulk export in open standards (ZIP containing XMLs).

2 Metadata Preservation: The export must include the reception date and audit logs.

3 Third-Party Archiving: This is why using a dedicated archive (like Peppol Archive) separates the risk. Your archive persists even if you change your accounting software.