Peppol self-billing with a subcontractor: preserve agreement and acceptance

Self-billing means the customer prepares the invoice in the supplier's name. In a construction subcontract, that changes who creates the document, but it does not remove the need to agree the arrangement or let the subcontractor accept each invoice. Keep those controls visible before the invoice enters the accounting flow.

Record the arrangement before the first invoice

Identify the legal parties, projects covered, start and review dates, method for sharing measured work, acceptance route and correction contact. Do not assume a clause in a general purchase order covers every subcontractor or every project.

The Belgian federal B2B e-invoicing FAQ states that self-billing remains allowed when there is prior agreement between the parties and a procedure for the supplier to accept each invoice. It also confirms that self-billing can use Peppol.

Build the invoice from reviewed project evidence

Before preparation, reconcile the period, work package, approved quantities, agreed rates, variation decisions and previous billing. A site timesheet or progress note may support the amount, but it is not automatically the subcontractor's invoice acceptance.

Make discrepancies explicit. If the principal contractor measured a different quantity, keep both positions and assign the difference for resolution. Do not quietly change the subcontractor's record or turn an estimate into accepted work.

Capture acceptance for the individual invoice

Send the subcontractor a readable view and the information needed to understand the structured invoice. Record who accepted it, when, and which invoice version was accepted. Silence should not be labelled acceptance unless the actual agreed procedure and applicable rules support that conclusion.

If the subcontractor rejects the invoice, keep the reason separate from the original document. Decide whether the data should be corrected, the commercial issue escalated or the invoice cancelled under the appropriate process. Avoid repeatedly issuing near-identical invoices while the disagreement remains open.

Keep Peppol and project controls distinct

Peppol BIS Billing provides a structured exchange framework. It does not prove that quantities were measured correctly, a variation was approved or the subcontractor accepted the invoice. Those decisions belong in the project and commercial record.

Finally, link the accepted invoice to the correct subcontractor and site cost. Enfin can connect that context, but this page does not claim that Enfin currently creates or approves self-billed invoices. Obtain accounting or legal advice before setting up a self-billing arrangement.

See how Enfin connects construction administration, review pricing, or discuss your workflow with us.