Annual Client Listing in Belgium (Klantenlisting): What It Is and How to File It
The annual client listing (klantenlisting / listing des clients assujettis) is a legal obligation for every VAT-registered business in Belgium. It must be submitted to the FOD Financiën by March 31 each year and covers all Belgian VAT-registered clients you invoiced above the €250 threshold in the previous calendar year. Many freelancers overlook it — here's everything you need to know.
What Is the Annual Client Listing?
The client listing is a structured report submitted to the Belgian tax authority (FOD Financiën / SPF Finances) listing every Belgian VAT-registered client you invoiced for more than €250 excl. VAT during the calendar year. It gives the tax authority a cross-reference to verify that the VAT your clients declared as recoverable matches the VAT you declared as collected.
Who Must File?
All VAT-registered Belgian businesses that:
- Made taxable supplies to other Belgian VAT-registered businesses (B2B)
- Had at least one client where the annual invoiced amount exceeded €250 excl. VAT
Even if you only have one qualifying client, you must file. If all your clients are private individuals (B2C), or if you operate under the VAT exemption for small businesses, you are exempt from this obligation.
What Information Is Required?
For each qualifying client you must report:
- Client's Belgian VAT number
- Total amount invoiced excl. VAT for the year
- Total VAT amount charged
Credit notes must be subtracted from the totals. If a client's net invoiced amount after credit notes falls below €250, they do not need to be included.
The €250 Threshold — Common Misunderstandings
- The threshold is per client per year — multiple small invoices that total more than €250 must be included
- It applies to the amount excl. VAT, not incl. VAT
- Credit notes reduce the total — a client invoiced for €300 with a €100 credit note has a net of €200 and does not need to be included
- Foreign clients are excluded — only Belgian VAT numbers are reportable
Deadline and Filing Method
The client listing for the previous calendar year must be submitted by March 31. For income year 2025, the deadline is March 31, 2026.
Filing options:
- Intervat — the FOD's online VAT platform (intervat.minfinbe)
- XML upload — generated by your accounting software
- Via your accountant — who files on your behalf
Penalties for Non-Filing
Late or non-filing can result in fines of €50 to €1,250 depending on circumstances. The FOD typically sends a reminder before imposing fines for first-time failures.
How Eurobillr Generates the Client Listing Automatically
Eurobillr tracks every invoice you send throughout the year. When March approaches:
- Go to Reports → Annual Client Listing
- Select the tax year
- Eurobillr automatically filters Belgian VAT-registered clients above the €250 threshold
- Applies credit notes to the correct client totals
- Download as PDF for review or XML for direct upload to Intervat
No manual calculation, no risk of missing a client, no spreadsheet required.