Client not on Peppol: what you can and cannot do
Decision tree when a Belgian B2B customer is unreachable on Peppol. Lookup failures, mandate limits, and remediation without fake workarounds.
Updated
- Belgium
One job: decide the next compliant step
Delivery fails because the buyer is not in the Peppol directory, or no Access Point accepts their participant ID. That is a routing failure, not a bad UBL file. For in-scope Belgian B2B under the structured e-invoicing obligation, non-reachability does not erase the duty to exchange structured invoices on Peppol.
Decision tree
Lookup failed?
├─ Wrong KBO/BCE or scheme 0208? → Correct ID, retry lookup
├─ Registered in last hours/days? → Wait for Directory visibility, retry
├─ Branch vs head-office ID? → Confirm legal entity that must receive
├─ Truly not registered? → Ask buyer to register; hold structured send; document attempts
└─ Still failing after registration? → Check they published BIS Billing receive capability
Always verify with a deliberate participant lookup before declaring the client "off Peppol."
| You can | You cannot (when mandate applies) |
|---|---|
| Retry lookup with the correct enterprise number | Treat PDF-by-email as the compliant exchange |
| Ask the customer to complete Peppol registration | Register the customer yourself as if you were their Access Point |
| Email a PDF as interim commercial communication | Claim the obligation paused because delivery failed once |
| Resubmit the structured invoice once they are reachable | Invent a permanent "customer not ready" exemption |
| Log timestamps, IDs tried, and customer contacts | Assume waiting indefinitely replaces structured sending |
What "unreachable" usually means
| Lookup outcome | Likely cause | Action |
|---|---|---|
| No participant | Never registered | Buyer onboarding to Peppol |
| Miss on known VAT number | Typo, old seat, wrong scheme | Fix master data |
| Participant exists, no invoice profile | Send-only or incomplete publish | Buyer must publish invoice receive |
| Intermittent miss after signup | Directory propagation delay | Retry on a schedule; do not switch permanently to PDF-only |
Practical sequence
- Confirm buyer enterprise number (scheme 0208) and legal entity.
- Run participant lookup; capture the error.
- Contact the buyer: registration + receive capability required for in-scope invoices.
- Keep a structured invoice ready; resend when lookup succeeds.
- If commercially urgent, share a PDF and keep the Peppol gap open until structured delivery works. PDF does not close compliance. See PDF versus structured invoice.
- Participant lookup failure
Directory miss that blocks Peppol routing before any invoice content is transmitted.