Belgium Imposes Strict Deadlines for 2026–2027 VAT Attestation Renewals

Context

The SPF Finances regulatory notice published on 21 September 2026 introduces a critical administrative window for vehicle dealers in Belgium. This window, opening on 1 October 2026 and closing on 28 February 2027, is the period during which wholesale and retail dealers must submit applications for VAT attestations required to renew merchant license plates. This process is essential for ensuring compliance with Belgian tax regulations and maintaining operational continuity for businesses that rely on merchant plates.

The notice also clarifies procedural changes, particularly the removal of VAT attestation requirements for trial and professional license plates. Dealers seeking these plate types must now apply directly to SPF Mobility and Transport, streamlining the process but adding complexity for those unfamiliar with the new procedures. Additionally, merchants may request additional merchant plates year-round without triggering an attestation renewal requirement, providing flexibility for businesses expanding their vehicle fleets.

What's Changing

The most pressing change is the compressed timeline for VAT attestation applications. SPF Finances requires up to 10 business days to process each application, and all completed files must be transmitted to the Vehicle Registration Directorate (DIV) by 28 February 2027. This creates an effective hard cutoff for submissions on 26 February 2027, as applications received after this date will not be processed. Moreover, those submitted after 15 February 2027 risk delayed processing, potentially resulting in missed deadlines.

A notable procedural complication arises from the fact that 28 February 2027 falls on a Sunday. SPF Finances has confirmed it will not operate weekend hours to accommodate late submissions, making the 26 February 2027 business-day cutoff absolute. This strict deadline underscores the urgency for dealers to submit their applications well in advance to avoid any disruptions in their merchant plate renewals.

Procedural Changes

The regulatory notice also introduces significant procedural changes. VAT attestations are no longer required for trial and professional license plates, which must now be obtained directly from SPF Mobility and Transport. This shift removes SPF Finances from the process entirely, simplifying the procedure for those seeking trial and professional plates but adding a layer of administrative distinctiveness that dealers must navigate.

Additionally, merchants wishing to request additional merchant plates beyond their existing allocation may do so year-round without triggering an attestation renewal requirement. This provision offers flexibility for businesses looking to expand their vehicle fleets but requires careful record-keeping to ensure compliance with other regulatory requirements.

Implications for Belgian Vehicle Dealers

For Belgian vehicle dealers, the immediate priority is to submit VAT attestation applications within the specified window. Given the processing time of up to 10 business days, dealers should aim to submit their applications as early as possible to avoid the risk of delayed processing or missing the absolute cutoff on 26 February 2027.

Dealers must also familiarize themselves with the new procedural changes, particularly the removal of VAT attestation requirements for trial and professional license plates. This change necessitates direct applications to SPF Mobility and Transport, requiring dealers to adapt their administrative processes accordingly.

Additionally, the year-round flexibility for requesting additional merchant plates offers strategic advantages. Dealers can plan their fleet expansions more effectively, ensuring they have the necessary resources without the administrative burden of attaining additional attestations.

Outlook / What to Watch

Looking ahead, dealers should closely monitor any further communications from SPF Finances regarding the attestation process. While the regulatory notice provides clear guidelines, additional clarifications or procedural adjustments may arise as the deadline approaches. Dealers should also stay informed about any potential changes in processing times or additional requirements that could impact their ability to meet the deadlines.

The procedural distinction between merchant, trial, and professional plates will likely require ongoing attention. Dealers must ensure they are applying through the correct channels to avoid delays or rejections.