Luxembourg Introduces Mandatory B2B E-Invoicing Regime from 2028 – Law submitted to Parliament

Summary

Source chd.lu (parliamentary document)

Luxembourg Introduces Mandatory Domestic B2B E-Invoicing

The Luxembourg government has submitted Bill 8815, proposing the introduction of mandatory electronic invoicing for domestic business-to-business transactions. The initiative would expand the country’s existing e-invoicing framework, which currently applies to public procurement, to cover taxable transactions between businesses established in Luxembourg.

The proposed rules would apply to invoices that are required under Luxembourg VAT legislation and issued by suppliers established in Luxembourg to recipients also established in Luxembourg for supplies of goods or services taxable in Luxembourg. Domestic B2B transactions would therefore become subject to mandatory structured electronic invoicing.

Structured Electronic Invoices Become the Legal Standard

Under the draft legislation, a valid electronic invoice must be issued, transmitted and received in a structured electronic format that enables automatic processing and complies with the applicable European e-invoicing standard and authorised syntaxes.

The bill explicitly confirms that commonly used formats such as PDF files, Microsoft Word documents, scanned invoices and image files do not qualify as compliant electronic invoices. While supporting documentation may still be attached to an invoice, only the structured electronic invoice itself will have legal validity.

Mandatory Acceptance and Self-Billing

Recipients will be required to receive and process compliant electronic invoices and will not be permitted to reject them solely because they are in electronic form. The proposal removes the traditional requirement for recipient consent to electronic invoicing for transactions within the scope of the new regime.

The draft law also preserves existing self-billing arrangements. Customers may continue to issue invoices on behalf of suppliers provided that a prior agreement exists and each invoice is approved by the supplier in accordance with Luxembourg VAT rules.

Common Delivery Network

Businesses will be required to use a common, interoperable and secure delivery network for exchanging electronic invoices. The network must support automated transmission, receipt and processing of invoices, while also enabling the exchange of related status messages and business documents.

Suppliers will additionally be required to receive and process response messages such as acknowledgements, validations, rejections and payment notifications. This approach is intended to facilitate end-to-end digitalisation and automation of invoicing processes.

The bill further prohibits suppliers from charging customers additional fees solely because an invoice is issued in compliant electronic format.

Phased Rollout Between 2028 and 2029

Implementation will take place in stages.

• From 1 January 2028: All affected businesses must be capable of receiving and processing compliant electronic invoices.
• From 1 July 2028: The obligation to issue electronic invoices will apply to businesses that exceed at least two of the following three thresholds:
  • Balance sheet total: EUR 7.5 million
  • Annual turnover: EUR 15 million
  • Average workforce: 50 employees
• From 1 January 2029: The obligation to issue compliant electronic invoices will extend to all remaining businesses within scope.

Transitional Measures for Smaller Businesses

Recognising that some businesses may face technical challenges, the proposal includes transitional and alternative solutions for entities with limited invoicing volumes or reduced technical capabilities. The detailed thresholds will be established through secondary legislation.

Where businesses exceed the relevant thresholds while using such alternatives, progressive usage fees may apply: EUR 2 per invoice for the first 20 invoices above the threshold; EUR 3 per invoice for the following 30 invoices; EUR 4 per invoice for the next 50 invoices; and EUR 5 per invoice thereafter.

Comparable fees may also apply to received invoices processed via the alternative channels.

Preparing Businesses for the Digital VAT Future

The explanatory notes accompanying the bill highlight that mandatory domestic e-invoicing will help Luxembourg businesses prepare for future EU digital VAT reporting obligations. The proposal is designed to accelerate digital transformation, improve invoice automation, reduce administrative burdens and strengthen interoperability between businesses.

With Belgium already operating a domestic B2B e-invoicing regime and similar developments underway across Europe, Luxembourg is positioning itself for the next phase of digital VAT compliance and transaction-based reporting.

External Links

External Links

• Luxembourg Parliament (Chambre des Députés): https://www.chd.lu
• Luxembourg Government: https://gouvernement.lu
• Luxembourg VAT Administration (AED): https://pfi.public.lu
• MyGuichet Luxembourg: https://guichet.public.lu/en/
• European Commission e-Invoicing: https://ec.europa.eu/digital-building-blocks/wikis/display/DIGITAL/eInvoicing
• Peppol Network: https://peppol.org
• Directive 2014/55/EU on e-Invoicing: https://eur-lex.europa.eu/eli/dir/2014/55/oj
• Directive (EU) 2025/516 (VAT in the Digital Age): https://eur-lex.europa.eu/eli/dir/2025/516/oj

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Luxembourg Introduces Mandatory B2B E-Invoicing Under Draft Law 8815

• Luxembourg’s Draft Law No. 8815 will introduce mandatory structured e-invoicing for domestic B2B transactions, aligned with the EU’s ViDA initiative.
• The mandate applies to Luxembourg-established taxable persons subject to VAT invoicing rules, with some VAT-exempt financial and insurance services excluded.
• The system will use the Peppol network, but no domestic real-time VAT e-reporting is planned at first.
• Rollout is phased: all businesses must receive e-invoices by Jan. 1, 2028; large and medium enterprises must issue them from July 1, 2028; small and micro-enterprises from Jan. 1, 2029.

Source: kpmg.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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