Luxembourg - B2B E-Invoicing: Timeline, Scope and Key Issues of Bill No. 8815

Bill No. 8815 provides for the introduction of structured e-invoicing for domestic transactions between businesses established in Luxembourg. Here is an analysis of the key provisions of this upcoming reform: timeline, businesses concerned, invoice format, transmission network, and VAT implications.

Luxembourg: From B2G E-Invoicing to B2B E-Invoicing

A brief reminder: E-invoicing is already mandatory in Luxembourg for public procurement and concession contracts (Business to Government, or “B2G”).

Bill No. 8815, submitted on 30 July 2026, proposes extending this obligation to domestic transactions between businesses established in Luxembourg. As this is still a bill, its provisions may be amended during the legislative process.

This extension is part of an already well-established trend: more than 1.54 million e-invoices were received in Luxembourg in 2025. In May 2026, approximately two-thirds of these invoices related to B2G transactions, while one-third concerned B2B transactions.

The bill therefore pursues two main objectives:

to strengthen the country’s competitiveness by further digitalising invoicing, purchasing, accounting and payment processes;
to prepare Luxembourg businesses for the future digital reporting requirements introduced under the European VAT in the Digital Age (ViDA) reform, starting on 1 July 2030.

However, these two stages should be distinguished.

Bill No. 8815 introduces a structured e-invoicing obligation for certain domestic transactions. It does not yet establish transaction-by-transaction reporting of invoicing data for intra-EU transactions to the Registration Duties, Estates and VAT Authority (Administration de l’enregistrement, des domaines et de la TVA – AEDT).

Scope – Transactions subject to e-invoicing in Luxembourg

This bill will not apply to all invoices issued or received by a Luxembourg business.

An invoice will fall within the scope of the obligation when the following conditions are met:

the issuer is established in Luxembourg;
the recipient is also established in Luxembourg;
the supply of goods or provision of services is taxable in Luxembourg;
the transaction is subject to an invoicing requirement under the VAT Law;
the transaction is not one of the transactions covered by Article 262 of Directive 2006/112/EC (VAT Directive).

The following are notably excluded:

invoices issued by a person who becomes a taxable person on an occasional basis as a result of the occasional supply of a new means of transport;
invoices addressed to persons temporarily treated as taxable persons under the so-called “housing VAT” scheme;
intra-EU distance sales of goods made to private individuals and deemed to be located in Luxembourg.

Transactions for which Article 63 of the Luxembourg VAT Law (LTVAL) exempts the taxable person from issuing an invoice are also excluded from the scope (in particular, certain financial transactions).

The reform will therefore primarily concern domestic B2B transactions.

N.B.: The mere existence of a Luxembourg VAT number for the supplier or customer is not sufficient to conclude that the transaction falls within the scope of e-invoicing. A business may have a Luxembourg VAT number without being established there.

The same business may therefore have to manage several categories of invoices in Luxembourg simultaneously:

mandatory compliant e-invoices;
compliant e-invoices issued voluntarily;
paper or PDF invoices;
transactions that are not subject to an invoicing obligation.

A VAT Mapping will be necessary to identify and secure the appropriate treatment for each transaction. Discover this service.

The phased implementation of e-invoicing in Luxembourg

The bill distinguishes between the obligation to receive e-invoices and the obligation to issue them.

Mandatory receipt as of 1 January 2028

As of 1 January 2028, recipients falling within the scope of the obligation will have to be able to receive and process any compliant e-invoice issued by a business established in Luxembourg, without requiring any prior approval procedure.

This obligation to receive e-invoices will also apply where the issuer voluntarily issues a compliant e-invoice, even though it was not required to do so for the transaction concerned. The obligation to accept e-invoices therefore prevents a compliant invoice from being rejected solely because it is issued in electronic format.

N.B.: The removal of the prior approval requirement does not apply to self-billing. Where a customer issues an invoice in the name and on behalf of its supplier, the prior agreement between the parties and the invoice acceptance procedure will remain applicable.

The ordinary processing of an invoice includes, in particular, its verification, any challenge or dispute where applicable, potentially a reasoned rejection, payment, and, more generally, its integration into accounting and administrative processes. The recipient must incorporate the invoice into a genuine management process comparable to the one currently used for processing PDF and paper invoices.

Companies will therefore not be able to wait until their own e-invoicing issuance deadline to prepare their systems.

However, transitional alternative technical solutions would be made available to businesses that are not yet directly connected to the PEPPOL common delivery network:

until 30 June 2028 for businesses exceeding at least two of the three thresholds set out in the bill;
until 31 December 2028 for businesses that do not exceed at least two of the three thresholds;
until 31 December 2028 where it is materially impossible for them to provide the 2025 data relating to at least one of the criteria.

These solutions will allow businesses to temporarily comply with the obligation to receive e-invoices, but will not exempt them from processing the invoices received.

The draft Grand-Ducal Regulation establishing the common delivery network and the alternative technical solutions made available for e-invoicing provides for a certified business area on MyGuichet.lu, allowing businesses to receive e-invoices and any related response messages.

Mandatory issuance from 1 July 2028 or 1 January 2029

The obligation to issue and transmit compliant e-invoices will be introduced in two stages. This obligation is not limited to simply issuing a compliant e-invoice. The issuer must also be able to receive and process, through the common network, the messages associated with the invoice. Businesses will therefore not only have to send invoices, but also manage the entire invoice processing lifecycle.

The issuance obligation will apply no later than 1 July 2028 to businesses that, at the end of financial year 2026, exceed at least two of the following three thresholds:

total assets exceeding €7.5 million;
net turnover exceeding €15 million;
an average number of more than 50 full-time employees.

For other businesses falling within the scope of the reform, the issuance obligation will apply no later than 1 January 2029.

The same 1 January 2029 deadline will apply where it is materially impossible for a business to provide at least one of the financial year 2026 data points required for its classification.

Financial year 2026 will therefore serve as the reference year for determining the timetable applicable to each business.

A compliant e-invoice

One of the key changes introduced by the bill concerns the very concept of an e-invoice.

A compliant e-invoice is defined as an invoice that:

complies with the European standard for electronic invoicing;
uses one of the syntaxes included in the list published in the Official Journal of the European Union.

The invoice must be structured and allow for automated processing. It should also be noted that the issuer may not charge the recipient any specific additional fee solely for issuing a compliant e-invoice.

In everyday practice, a PDF sent by email is often considered an e-invoice. It may indeed continue to fall within the general definition of an invoice under the VAT Law.

However, it will not constitute a compliant e-invoice within the meaning of the new regime.

The bill specifies that only the compliant e-invoice will be legally recognized as the invoice.

A PDF representation may continue to accompany the structured file to facilitate readability. Other supporting documents may also be attached, such as a delivery note, service report or detailed statement.

However, these documents will not be considered the invoice itself.

Mandatory information

Compliance with the European semantic model alone is not sufficient to make an invoice legally complete.

A compliant e-invoice must include:

the mandatory information required under the VAT Law;
the company name, legal form and RCS number required under company law;
the business permit number where such a permit is legally required.

In the event of any discrepancy between the structured file and its PDF representation, the bill therefore gives decisive importance to the data contained in the structured invoice.

Credit notes and corrective invoices: also subject to the structured format

The bill also adapts the treatment of documents that modify an original invoice.

Where a compliant e-invoice is corrected, the corrective document must:

refer specifically and unambiguously to the original invoice;
be issued in the same structured format as the original invoice.

A credit note or debit note relating to a structured invoice therefore cannot be validly processed using a standalone PDF.

Businesses will need to adapt the entire invoice lifecycle, rather than merely the initial issuance of the invoice.

How will e-invoices be transmitted?

The bill and the draft Grand-Ducal Regulation provide that the issuance, transmission and receipt of e-invoices will be carried out through a single common delivery network, PEPPOL.

Alternative solutions for low invoice volumes

The bill provides for several alternative technical solutions.

Some of these will allow compliant e-invoices to be issued manually and individually by businesses that do not yet have an automated solution. Businesses will be able to use the alternatives introduced since 2022, namely:

an online form available on MyGuichet.lu, allowing businesses to issue and transmit a compliant e-invoice to the recipient by manually entering the invoice details into the form fields and submitting the completed form;
an online form available on MyGuichet.lu, allowing businesses to issue and transmit a compliant e-invoice to the recipient by uploading an e-invoice that is already compliant and submitting the completed form;
a certified professional area on MyGuichet.lu, allowing businesses to receive response messages.

These solutions are, however, intended for low invoice volumes, with the thresholds set by the draft Grand-Ducal Regulation:

75 e-invoices for issuance and transmission;
150 e-invoices for receipt.

If the threshold is exceeded, the bill provides for progressive usage fees for each additional invoice:

€2 excluding VAT for each of the first 20 invoices above the threshold;
€3 excluding VAT for each of the next 30 invoices;
€4 excluding VAT for each of the next 50 invoices;
€5 excluding VAT for each additional invoice beyond the first 100.

The same principle will apply to received invoices.

These amounts are not presented as fines, but rather as usage fees intended to discourage businesses from relying on alternative solutions on a long-term basis when their invoice volumes justify an automated connection to the common network.

What are the main risks for businesses?

At this stage, the bill does not provide for a specific standalone scale of fines for each breach of the e-invoicing obligation.

This does not, however, mean that a lack of preparation would be without consequences.

The main risks will include, in particular, commercial risks:

the inability to receive invoices from suppliers;
the technical rejection of issued invoices;
processing or payment delays;
high costs resulting from prolonged use of alternative solutions beyond the applicable thresholds.

There will also be tax risks:

denial of the right to deduct VAT in respect of a non-compliant invoice;
fines for breaches of the requirements of the VAT Law;
missing or incorrect mandatory information in the structured data;
the large-scale replication of an incorrect VAT treatment;
incorrect processing of credit notes or corrective invoices.

E-invoicing will automate processes, but it will also automate any configuration errors.

An error relating to the VAT rate, place of taxation, exemption, VAT number or customer classification could be replicated across a significant volume of transactions before being detected.

How should businesses prepare?

The first step is to map purchasing and sales flows in order to determine which transactions will fall within the scope of the reform.

This analysis should identify:

incoming and outgoing invoices and their processing workflows;
the place of establishment of the parties;
the place of taxation of the transaction;
the VAT treatment applied and the related invoice information;
processes relating to corrective invoices;
self-billing processes;
the nature of the transactions, whether domestic or international.

Businesses should then:

determine whether an invoicing obligation applies;
determine their e-invoice issuance deadline based on their 2026 financial year data;
ensure that they will be able to receive compliant e-invoices as of 1 January 2028;
ensure the reliability of their customer and supplier data;
identify the source data within their ERP systems;
adapt invoicing rules, invoice information and internal VAT controls;
map exemption scenarios to the relevant PEPPOL codes;
organise the management of respons;
review their processing and retention procedures;
prepare testing scenarios with their service providers and business partners.

2027 will therefore be a critical year for the design, integration and testing of the new solutions.

VAT Solutions Luxembourg supports you in analysing your VAT flows

E-invoicing is not solely an IT project.

Determining its scope relies directly on VAT concepts, including the place of taxation, the invoicing obligation, exemptions, the reverse charge mechanism and mandatory invoice information.

VAT Solutions supports businesses in mapping and assessing the VAT treatment of their flows, identifying transactions subject to e-invoicing, reviewing data and system configurations, and translating VAT rules into functional requirements for ERP systems.

An early analysis will help secure compliance, manage the implementation timeline effectively, and make full use of the automation of invoicing and accounting processes.

For businesses involved in transactions concerning goods, which are also directly affected by the other changes introduced by the ViDA Directive as of 1 July 2028 (the so-called “single VAT registration” pillar), this is also an opportunity to identify the flows that need to be analysed.

Has your business already identified the invoices it will need to receive in structured format as of 1 January 2028, and those it will need to issue in this new format from July 2028 or January 2029?

This article is based on Bill No. 8815 as submitted on 30 July 2026. The text, timetable and practical arrangements may be amended during the legislative process and when the implementing Grand-Ducal Regulations are adopted.