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Luxembourg formalises phased mandatory B2B e-invoicing timeline

Luxembourg’s government has taken a decisive step to digitalise its commercial landscape by expanding e-invoicing beyond public sector contracts, with B2B requirements set to begin in 2028.

Following approval by the Government Council, Minister of Finance Gilles Roth submitted Draft Law 8815 to the Chamber of Deputies, outlining a phased transition to mandatory domestic B2B structured e-invoicing.

The new framework aligns Luxembourg with the European Union’s VAT in the Digital Age (ViDA) initiative and transitions the country away from a voluntary B2B approach.

Key deadlines:

1st January 2028: All taxable people established in Luxembourg will be required to take receipt of and process compliant e-invoices.

1st July 2028: Issuance and transmission of e-invoices will become mandatory for large and medium-sized businesses.

1st January 2029: Mandatory e-invoicing will apply to all remaining entities, including small companies and micro-businesses.

Under the proposed rules, traditional billing formats like unstructured PDFs, Word documents, or scanned images will no longer legally qualify as electronic invoices. Transactions must use structured formats that align with the European standard EN 16931and utilise approved XML syntaxes to allow automated computer processing.

To transmit these documents, the government intends to reuse its existing public sector (B2G) infrastructure.

This framework relies on the four-corner Peppol network for secure interoperability. To facilitate a smooth rollout for smaller entities, alternative transitional tools – such as manual input and retrieval via state portals like MyGuichet.lu – are expected to be available.

Crucially, Luxembourg’s current focus is restricted exclusively to e-invoicing. Unlike more complex models introduced by European neighbours, Luxembourg has opted not to launch a parallel domestic real-time transaction reporting regime to the tax authorities.

Instead, this legislation acts as a technical stepping stone, preparing local companies for the EU-wide cross-border Digital Reporting Requirements (DRR) scheduled to take effect under ViDA on 1st July 2030.

To ensure compliance before the deadlines, businesses established in Luxembourg should immediately assess their current e-invoicing infrastructure.

Companies need to audit their existing software systems to verify they can generate and process structured XML formats matching the EN 16931 standard.

Since the mandate relies heavily on the four-corner architecture, early registration with an approved Peppol Access Point provider is also highly recommended.