Electronic invoice in Luxembourg

Requirements, formats, and transmission methods for electronic invoices to public contracting authorities in Luxembourg.

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Overview

Luxembourg has fully implemented electronic invoicing in the public sector and ranks among Europe's front-runners in B2G e-invoicing. All suppliers — domestic and foreign alike — must send their invoices to Luxembourg public bodies electronically.

Unlike many neighbouring countries, Luxembourg created no central government portal. It relies entirely on the Peppol network instead. With the draft law approved in July 2026, the obligation is being extended step by step to domestic B2B transactions.

All suppliers

in public procurement, domestic and foreign

Peppol

the statutory delivery network instead of a state portal

10 years

retention period for invoices and accounting records

Timeline

The B2G sphere has been fully converted since 2023. For B2B, the Government Council approved a draft law on 17 July 2026 providing for a phased rollout between 2028 and 2029.

Already in force

16 May 2019

Law transposing EU Directive 2014/55/EU

Public contracting authorities must accept and process compliant e-invoices: central bodies from 18 April 2019, sub-central authorities such as municipalities from 18 April 2020.

13 December 2021

Amending law and Grand-Ducal Regulation

The amending law extends the obligation to economic operators. The accompanying regulation designates Peppol as the common delivery network and defines the manual fallback options.

18 May 2022 – 18 March 2023

Phased rollout in the B2G sphere

Large operators from 18 May 2022, medium-sized from 18 October 2022, small and newly formed businesses from 18 March 2023. The obligation has applied without exception since.

17 July 2026

Government Council approves the B2B draft law

The Cabinet adopts a draft law and Grand-Ducal Regulation extending the e-invoicing obligation to domestic B2B transactions.

Planned deadlines

1 October 2026

XRechnung versions below 3.0 no longer accepted

This covers invoices and credit notes in both UBL and CII. German suppliers still using XRechnung 2.2.0 or 2.3.1 need to act.

1 January 2028

B2B receiving obligation for all businesses

Every business must be able to receive and process electronic invoices, regardless of size.

1 July 2028

B2B issuing obligation for large and medium-sized businesses

Large and medium-sized businesses must issue their domestic B2B invoices electronically.

1 January 2029

B2B issuing obligation for all remaining businesses

The issuing requirement extends to all remaining businesses, including micro-enterprises and sole traders.

1 July 2030

ViDA cross-border reporting

The EU-wide Digital Reporting Requirement for intra-community B2B transactions takes effect and replaces EC Sales Lists. It is implemented through a separate companion bill.

The B2B element is so far a draft law, not enacted legislation. The definitive scope, sequencing and technical standard will only be fixed as the bill passes through Parliament. Treat the dates as a firm indication of direction rather than a guaranteed statutory deadline.

B2G today

The legal basis is the Law of 16 May 2019 as amended by the Law of 13 December 2021. It applies to all invoices under public contracts and concession contracts — irrespective of the invoice amount or the procurement procedure used.

—Economic operators may only issue and transmit structured XML invoices

—Public bodies receive via Peppol; ministries and state administrations via the access point of the CTIE

—No de minimis threshold — the obligation applies from the first euro

—A scanned paper invoice or a PDF sent by email is not an electronic invoice

Size categories under the law

The figures at the 2019 balance sheet date were decisive. The classification determined which deadline applied:

LargeBalance sheet total above €20m, turnover above €40m or more than 250 employees — obligation from 18 May 2022

MediumBalance sheet total €4.4–20m, turnover €8.8–40m, 50–250 employees — obligation from 18 October 2022

Small / newBalance sheet total below €4.4m, turnover below €8.8m, up to 50 employees — obligation from 18 March 2023

B2B mandate from 2028

The draft law approved on 17 July 2026 carries the model already proven in the public sector into private-sector trade. It applies to domestic B2B transactions between businesses established in Luxembourg. Invoices will have to be exchanged in structured, machine-readable form.

The sequencing is deliberate: receiving capability is established across the market first, and only then does the issuing obligation begin — staggered by company size.

E-invoicing — yes

Structured invoices are exchanged directly between businesses over Peppol. The tax administration is not a party to that exchange.

Domestic e-reporting — no

The draft contains no ongoing reporting of invoice data to the tax administration. This sets Luxembourg clearly apart from France and Belgium.

The only future reporting obligation stems from EU law: the cross-border Digital Reporting Requirement under ViDA from 1 July 2030 for intra-community B2B transactions. For purely domestic transactions, businesses simply exchange invoices and stop there. That means noticeably less implementation effort than in neighbouring markets.

Scope

B2G Fully mandatory. Every invoice to a Luxembourg public body must be transmitted electronically — for all suppliers, regardless of size or country of origin.

B2B Voluntary today, mandatory later. Many businesses already use Peppol for efficiency reasons. Under the draft law the obligation begins in 2028.

B2C No obligation. Invoicing consumers remains outside the scope; conventional receipts and PDF invoices continue to be acceptable.

Important for foreign suppliers

If you are a foreign business supplying a Luxembourg public body, you are subject to exactly the same obligation as domestic providers. The law attaches to participation in the public contract, not to where the business is established. Connecting through a certified Peppol Access Point makes cross-border compliance straightforward.

Formats and standards

Every electronic invoice must comply with the European standard EN 16931-1:2017 and use one of the two permitted syntaxes. Luxembourg applies the pure European standard — with no national CIUS or local deviations, which considerably simplifies cross-border compatibility.

XML UBL 2.1

Universal Business Language under ISO/IEC 19845:2015, maintained by OASIS. In practice by far the most common format, via Peppol BIS Billing 3.0.

XML UN/CEFACT CII

Cross Industry Invoice under XML schemas 16B (SCRDM – CII). Permitted, but noticeably less used than UBL.

From 1 October 2026 Luxembourg no longer accepts XRechnung versions below 3.0 — neither for invoices nor credit notes, in UBL or CII. If your system still produces XRechnung 2.2.0 or 2.3.1, migrate straight to a current 3.0 release.

The Peppol model

The Grand-Ducal Regulation of 13 December 2021 designates Peppol as the common delivery network. Exchange follows the four-corner model: the sender passes the invoice to its access point, which routes it across the network to the recipient's access point, which delivers it into the recipient's system. No government platform sits in the transmission path.

Usable across borders

The same connection works for every Peppol country — no separate link per trading partner.

Secure transmission

Encrypted communication between access points and non-repudiation of delivery.

Open and interoperable

Once on the network you can exchange with any other participant — private sector and international included.

More than invoices

The same connection carries orders, catalogues and other structured documents.

Addressing requires the recipient's Peppol identifier (EndpointID) — in Luxembourg the identification number from the trade register, or the VAT number during a transitional period. Public bodies are listed in an official directory.

Ways to connect

There are several routes onto the Peppol network. Which one fits depends mainly on invoice volume and your existing systems.

Certified Peppol Access Point

Connection through a specialised provider, coupled to your ERP or invoicing software. The provider does not need to be based in Luxembourg. The right route for regular invoice volumes and for receiving.

ERP or accounting software with a Peppol module

Many systems ship with Peppol sending built in. Check whether the module is activated and whether receiving is supported as well.

Online forms on Guichet.lu

Two non-automated forms are available: manual entry of the invoice data, or upload of an already compliant file. Intended as a transitional option for very low volumes — and only for sending, not receiving.

Your own access point

Technically possible, but only worthwhile for larger organisations with an in-house IT function and the resources to run it.

Retention

Invoices and accounting records must be kept in Luxembourg for ten years, counted from the end of the financial year to which they relate. Electronic retention is permitted provided authenticity of origin, integrity of content and legibility are assured throughout.

The structured XML file is the legally authoritative original and must be archived unchanged — a PDF rendering is not sufficient

Responsibility stays with the business even where a service provider handles storage technically

A reliable audit trail linking invoice, supply and payment must be documented and traceable

Because the invoice already exists in electronic form, the detour through paper or scanned archives disappears. This is one of the side effects of the transition that becomes noticeable fastest in practice.

How we help

As a certified Peppol Access Point we connect your system to Luxembourg recipients — and to the rest of the Peppol network at the same time:

Sending and receiving through a certified Peppol Access Point

Peppol BIS Billing 3.0 (UBL 2.1) and UN/CEFACT CII

Support for current XRechnung 3.0 versions

Format conversion from ERP, CSV and IDoc data

Validation against EN 16931 before transmission

Integration via API, SFTP and CSV

Traceable status and error feedback

Preparation for the upcoming B2B mandate from 2028

Frequently asked questions

Is electronic invoicing mandatory in Luxembourg?

In the B2G sphere, yes: since 18 March 2023 all suppliers must send their invoices to public bodies electronically. In B2B it is currently voluntary — under the draft law approved in July 2026 the obligation is due to phase in from 2028. No obligation is planned for B2C.

Which formats are accepted?

XML invoices compliant with EN 16931-1:2017 in either UBL 2.1 or UN/CEFACT CII syntax. In practice Peppol BIS Billing 3.0 on a UBL basis dominates. A PDF is not an electronic invoice — not even when sent by email.

How do I send an e-invoice to a Luxembourg public body?

Through Peppol-enabled software or a certified access point. Small suppliers may use the online forms on Guichet.lu as a transitional option. In all cases you need the recipient's Peppol identifier — the trade register identification number, or the VAT number during the transitional period.

Do foreign businesses have to comply?

Yes. Any foreign business participating in a Luxembourg public contract is subject to the same obligation. Connecting through a certified Peppol provider makes cross-border compliance straightforward — and the same connection can be reused for other countries.

Is there a de minimis threshold for small invoice amounts?

No. Every invoice issued to a public body under a written contract falls within the scope of the law — regardless of the amount and of the procurement procedure used.

What happens if I do not send an e-invoice?

Public bodies no longer process paper or PDF invoices, which can delay payment considerably. Although the law provides no specific fines, non-compliance can affect the business relationship and eligibility for future contracts.

Do I have to report invoice data to the tax administration?

Not for purely domestic transactions. Unlike France or Belgium, Luxembourg plans no domestic e-reporting. The only future reporting obligation is the EU-wide cross-border Digital Reporting Requirement under ViDA, from 1 July 2030, for intra-community B2B transactions.

How long must I retain electronic invoices?

Ten years from the end of the financial year concerned. The structured XML file must be kept as the original, and authenticity, integrity and legibility must be assured throughout the period.

Summary

Luxembourg is among Europe's front-runners in B2G e-invoicing. Since March 2023 electronic invoicing has been mandatory for all suppliers to the public sector — domestic and foreign, with no amount threshold and no exemption by company size.

Unlike many other countries, no central government portal was built. Luxembourg relies entirely on the decentralised Peppol network and the pure European standard EN 16931, with no national deviations. That makes cross-border implementation considerably simpler than in countries operating their own clearing portal.

The draft law of July 2026 extends this model to domestic B2B, phased across 2028 and 2029 and still on a Peppol basis. What the draft does not contain is notable: any domestic obligation to report invoice data. That leaves Luxembourg the lightest-touch route in Western Europe.

Businesses already invoicing the public sector over Peppol hold most of the infrastructure that will be required for B2B from 2028. The transition widens an existing pipe rather than laying a new one.

Resources

Ministry for Digitalisation – Electronic invoicing in Luxembourg The official overview: legal framework, deadlines, technical solutions and glossary efacturation.public.lu – national information portal Joint portal of the Ministry, the Chamber of Commerce and the Chamber of Skilled Trades Directory of public bodies addressable via Peppol Official list with the corresponding Peppol identifiers (EndpointID) Legilux – Law of 16 May 2019 (consolidated version) The legal basis for e-invoicing in public procurement (in French) Legilux – Grand-Ducal Regulation of 13 December 2021 Designates Peppol as the common delivery network and defines the alternatives (in French) Guichet.lu – enter an e-invoice manually Online form for manual entry; a companion form allows uploading a ready-made file Peppol Directory Registry of published network participants and their identifiers

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