On 30 July 2026, the Luxembourg Government submitted draft law No.8815 (the “Draft Law”), extending the existing mandatory electronic invoicing framework beyond public procurement and concession contracts to certain domestic business-to-business (“B2B”) transactions.
The Draft Law amends the law of 16 May 2019 on electronic invoicing and the amended law of 12 February 1979 on VAT. It also aims to prepare Luxembourg businesses for the digital reporting requirements introduced at EU level under the VAT in the Digital Age (“ViDA”) Directive (EU) 2025/516 of 11 March 2025.
As the legislative process is still ongoing, the proposed implementation arrangements remain subject to further clarification and may be amended before their final adoption.
Scope of the new regime
The proposed rules would apply to domestic B2B transactions, where the supplier and customer are established in Luxembourg, the transaction is taxable in Luxembourg, and an invoicing obligation exists under Luxembourg VAT rules. Certain categories of invoices would be excluded from the regime, including invoices issued by occasional taxable persons, invoices issued to persons temporarily acquiring taxable person status under the housing VAT regime, and invoices relating to intra-EU B2C distance sales taxable in Luxembourg.
The proposed regime would therefore not constitute a general e-invoicing obligation for all invoices issued by Luxembourg businesses. Its application will depend on the characteristics of the relevant transaction and on the applicable VAT rules.
A compliant electronic invoice will be required
A key element of the reform is the distinction between an electronic invoice in the broad sense and a “compliant electronic invoice”.
A PDF sent by email may qualify as an electronic invoice in the broad VAT sense but would not constitute a compliant electronic invoice for the purposes of the proposed mandatory regime.
A compliant electronic invoice means an invoice issued, transmitted and received in a structured format capable of automated processing and comply with the applicable European standard and authorised syntax.
The compliant electronic invoice would constitute the legally relevant invoice, while a PDF could only serve as a readable representation or accompanying document.
A three-step implementation
The reform introduces a phased timetable:
- From 1 January 2028: all Luxembourg businesses within scope must be able to receive and process electronic invoices.
- From 1 July 2028: businesses that exceed at least two of three size thresholds (balance sheet total of EUR 7,500,000, net turnover of EUR 15,000,000 and 50 full-time employees) at the closing date of their 2026 financial year must issue and transmit electronic invoices.
- From 1 January 2029: the issuance and transmission obligation will extend to all other businesses within the scope, including those that do not exceed the above thresholds or that are unable to provide the relevant size data for 2026.
The Draft Law also provides for transitional arrangements for the receipt of compliant electronic invoices during 2028. During this period, businesses that are not yet connected to the common delivery network may use transitional alternative technical solutions: until 30 June 2028 for businesses exceeding the size thresholds, and until 31 December 2028 for smaller businesses and those unable to provide the relevant size data for 2026.
Peppol as the common delivery network
The Draft Law provides for a common delivery network for the issuance, transmission and reception of compliant electronic invoices.
The Draft Law provides that the common delivery network will be determined by Grand-Ducal Regulation. The Luxembourg Government has indicated that the existing Peppol network used for public procurement is intended to be reused for this purpose.
Alternative technical solutions will also be available on a permanent basis for businesses with limited invoicing volumes, subject to thresholds to be set by Grand-Ducal Regulation. Businesses exceeding those thresholds through alternative solutions would be subject to escalating per-invoice usage fees.
Impact on internal processes
The reform goes beyond the technical format of invoices. Businesses will need to ensure that their systems and internal procedures enable the receipt and processing of structured electronic invoices and, for Luxembourg-established issuers, the processing of return messages, including confirmations, rejections and error notifications.
No national real-time reporting at this stage
The proposed Luxembourg regime should be distinguished from the future EU digital reporting requirements under ViDA. At this stage, the Draft Law does not introduce a general real-time reporting obligation to the Luxembourg VAT authorities for domestic B2B invoices. However, from 1 July 2030, ViDA will introduce digital reporting requirements for intra-Community transactions based on electronic invoice data.
Practical impact
Businesses should start preparing ahead of 2028 by:
- identifying transactions falling within the scope of the new rules;
- determining their applicable issuance and transmission deadline;
- assessing the ability of their ERP and invoicing systems to generate and process compliant structured invoices;
- reviewing master data and internal invoice workflows; and
- assessing the appropriate technical solution, including connection to Peppol network or, where applicable, an alternative solution.
Conclusion
The Draft Law would significantly extend Luxembourg’s existing e-invoicing framework to domestic B2B transactions. The phased implementation provides businesses with a period to adapt their systems and procedures. Nevertheless, 1 January 2028 constitutes a key compliance date, as businesses within scope would be required to receive and process compliant electronic invoices from that date.
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