Suppliers to Luxembourg public bodies under procurement and concession contracts have had to send e-invoices, over Peppol or MyGuichet.lu forms, since 18 March 2023. Bill 8815, deposited on 30 July 2026, would extend the duty to domestic B2B: reception from 1 January 2028, then issuing from 1 July 2028 for larger issuers and from 1 January 2029 for the rest.
Last updated 30 Sep 2026
The law of 16 May 2019 transposed Directive 2014/55/EU and requires public bodies to receive and process compliant e-invoices: central bodies since 18 April 2019, sub-central bodies and contracting entities since 18 April 2020. Suppliers under public procurement or concession contracts followed in three waves from 18 May 2022, and since 18 March 2023 the duty to send e-invoices covers every economic operator under such a contract.
A domestic B2B mandate is proposed. The Minister of Finance, Gilles Roth, submitted bill 8815 on 30 July 2026 to extend the obligation to transactions between companies established in Luxembourg, transposing Article 1 of Directive (EU) 2025/516. Parliament has yet to vote on it. On 18 September 2026 the Chamber's Finance Committee heard the bill and appointed Laurent Mosar as rapporteur, and some deputies raised concerns about the capacity of small businesses to adapt.
From 1 October 2026, XRechnung versions below 3.0 are no longer accepted, whether sent over Peppol or uploaded through the MyGuichet.lu web form. The B2B dates come from Articles 12 and 13 of bill 8815 and stay proposals until the law passes: recipients in scope would receive and process compliant e-invoices from 1 January 2028, larger issuers would issue from 1 July 2028, and all other issuers from 1 January 2029.
Intra-EU B2B e-invoicing and digital reporting follow on 1 July 2030 under Directive (EU) 2025/516. Select a milestone below for its detail.
Under the law of 16 May 2019, which transposed Directive 2014/55/EU, central contracting authorities must receive and process compliant e-invoices from 18 April 2019.
Sub-central contracting authorities and contracting entities must receive and process e-invoices by 18 April 2020 under Article 6 of the law of 16 May 2019. The deferral does not cover central purchasing bodies.
A grand-ducal regulation of 13 December 2021 designated Peppol, maintained by OpenPeppol, as the common delivery network for public bodies' automated receipt of e-invoices, with two online forms as the alternative for suppliers.
Large economic operators must issue e-invoices to public bodies from 18 May 2022, the first of three waves listed in the government's February 2023 press briefing.
Medium-sized economic operators follow from 18 October 2022, the second wave listed in the government's February 2023 press briefing.
Since 18 March 2023 the obligation to send compliant e-invoices via Peppol or MyGuichet.lu applies to all economic operators under a public procurement or concession contract.
Directive (EU) 2025/516 was published on 25 March 2025. Under the amended Article 218, Member States may require taxable persons established in their territory to issue e-invoices for domestic supplies.
The government council approved a draft bill extending the e-invoicing obligation, so far limited to public procurement and concession contracts, to domestic commercial transactions between businesses established in Luxembourg, with a draft grand-ducal regulation on the delivery network.
The Minister of Finance, Gilles Roth, submitted bill 8815 to extend the e-invoicing obligation to domestic transactions between companies established in Luxembourg. The government portal says it would reuse the Peppol network already used in public procurement.
The bill was presented to the Chamber's Finance Committee, which appointed Laurent Mosar as rapporteur. Some deputies raised concerns about the capacity of small businesses to adapt.
XRechnung formats below version 3.0 are no longer accepted, whether sent over Peppol or uploaded through the MyGuichet.lu web form.
Member States apply Article 2 of Directive (EU) 2025/516 from 1 January 2027. It widens the deemed-supplier rule for electronic interfaces that facilitate supplies of goods within the EU by non-EU sellers.
Under Article 13 of bill 8815, the law would enter into force on 1 January 2028, when recipients in scope must receive and process any compliant e-invoice. Transitional alternative reception solutions run until 30 June or 31 December 2028.
Article 12 of bill 8815 applies the duty to issue from 1 July 2028 to issuers that exceeded two of three thresholds at the 2026 balance sheet date: EUR 7.5 million balance sheet, EUR 15 million turnover, 50 full-time staff.
Member States apply Article 3 of Directive (EU) 2025/516 from 1 July 2028. The deemed-supplier rule for short-term accommodation and passenger transport platforms may start as late as 1 January 2030.
All other issuers, including those unable to supply their 2026 figures, must issue compliant e-invoices from 1 January 2029 under Article 12 of bill 8815.
Member States apply Article 5 of Directive (EU) 2025/516 from 1 July 2030, which brings in structured e-invoices and digital reporting for intra-Community B2B supplies.
Every economic operator invoicing a Luxembourg public body under a public procurement or concession contract must send compliant e-invoices, over Peppol or through the MyGuichet.lu online forms; email is not a channel. Public bodies must receive and process them.
Bill 8815 would cover domestic invoices between issuers and recipients established in Luxembourg. An issuer would count as larger if it exceeded two of three thresholds at the 2026 balance sheet date: EUR 7.5 million balance sheet, EUR 15 million turnover and 50 full-time staff. Recipients above the thresholds may use transitional alternative solutions for reception until 30 June 2028, the rest until 31 December 2028, and a compliant e-invoice would no longer need the buyer's acceptance. The table below lists what falls outside each regime.
| Transaction | Obligation | Scope | Effective |
|---|---|---|---|
| B2B | Receive | All recipients in scope | 1 January 2028 (proposed) |
| B2B | Issue | Larger issuers; Two of: EUR 7.5m balance sheet, EUR 15m turnover, 50 staff (2026) | 1 July 2028 (proposed) |
| B2B | Issue | All other issuers | 1 January 2029 (proposed) |
| B2G | Issue | Large economic operators | 18 May 2022 |
| B2G | Issue | Medium-sized economic operators | 18 October 2022 |
| B2G | Issue | Small and newly established economic operators | 18 March 2023 |
| Who | What applies | Source |
|---|---|---|
| Public procurement derogations | Outside the B2G issuance duty | Official source |
| Proposed domestic B2B exclusions | Outside the proposed B2B scope | bill 8815 |
Luxembourg uses a decentralised model with no real-time digital VAT reporting requirement. A grand-ducal regulation of 13 December 2021 designated Peppol, maintained by OpenPeppol, as the common delivery network for public bodies' automated receipt of e-invoices, with two online forms as the alternative for suppliers. B2G invoices and credit notes follow EN 16931, as Peppol BIS Billing 3.0 in UBL or XRechnung 3.0.1 in UBL or CII syntax. FAIA, the national SAF-T file, is available on request.
Under bill 8815, B2B invoices would be issued, transmitted and received over a single common delivery network, designated by a grand-ducal regulation against nine criteria, and the government portal says the bill would reuse the Peppol network already used in public procurement. Taxable persons must keep copies of the invoices they issue and all invoices they receive for 10 years from the date of issue, per Guichet.lu.
| Document | Used for | B2B | B2G | B2C |
|---|---|---|---|---|
| Peppol BIS Billing 3.0UBL | B2G invoices and credit notes, over Peppol or MyGuichet.lu | · | · | |
| XRechnung 3.0.1UBL or UN/CEFACT CII | B2G invoices and credit notes; versions below 3.0 not accepted from 1 October 2026 | · | · |
For B2G, a file uploaded through MyGuichet.lu that does not comply with the European standard, or cannot be forwarded, produces an error message and does not reach the public body. Bill 8815 would add a usage fee: an issuer or recipient that exceeds the caps set for the permanent alternative solutions would pay EUR 2 to EUR 5 per invoice, excluding VAT.
| Offence | Penalty | Source |
|---|---|---|
| B2G non-compliant submissions | Not forwarded to the public body | produces an error message |
| Proposed alternative-solution usage fee | EUR 2 to EUR 5 per invoice, excl. VAT | bill 8815 |
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Luxembourg finally has a text. Bill 8815 was deposited in the Chamber on 30 July and would extend the 2019 e-invoicing law to domestic B2B. The dates in the deposited version are…
Does the bill actually name Peppol for the B2B leg, or is that left open? We are already on Peppol for the public sector side and would rather not run two routes.
For B2G, yes: every economic operator under a public procurement or concession contract has had to send compliant e-invoices since 18 March 2023. For domestic B2B, bill 8815 would make reception mandatory from 1 January 2028 and issuing from 1 July 2028 or 1 January 2029, but parliament has yet to vote on it. B2C has no requirement.
Under Articles 12 and 13 of bill 8815, deposited on 30 July 2026: recipients in scope from 1 January 2028; issuers that exceeded two of three thresholds at the 2026 balance sheet date (EUR 7.5 million balance sheet, EUR 15 million turnover, 50 full-time staff) from 1 July 2028; and all other issuers, including those unable to supply their 2026 figures, from 1 January 2029. The dates are proposals until the bill is voted.
Central public bodies have had to receive and process e-invoices since 18 April 2019, and sub-central bodies and contracting entities since 18 April 2020. Suppliers followed in three waves: large economic operators from 18 May 2022, medium-sized ones from 18 October 2022, and small and newly established ones from 18 March 2023.
The B2G duty does not apply to public procurement contracts for development cooperation, by diplomatic missions or consulates, for exhibitions abroad, or for State, official or working visits abroad. Bill 8815 would leave out invoices from occasional sellers of new means of transport, invoices to buyers under the TVA logement housing scheme, intra-Community distance sales of goods to private individuals deemed to take place in Luxembourg, and Article 262 supplies.
For B2G, EN 16931 invoices and credit notes as Peppol BIS Billing 3.0 in UBL or XRechnung 3.0.1 in UBL or CII syntax. XRechnung 2.2.0 and 2.3.1, obsolete since 2023 and 2024, are no longer accepted from 1 October 2026. Under bill 8815, B2B invoices would follow EN 16931 in a syntax on the EU list.
Yes, through the MyGuichet.lu online forms, which the grand-ducal regulation of 13 December 2021 designated as the alternative to Peppol. Invoices sent by email are not accepted.
Taxable persons must keep copies of the invoices they issue and all invoices they receive for 10 years from the date of issue. Accounting documents must be kept for 10 years, or 5 years in the event of liquidation, in electronic or paper format.
A file uploaded through MyGuichet.lu that does not comply with the European standard, or cannot be forwarded, produces an error message instead of reaching the public sector body.
An issuer or recipient that exceeds the caps a grand-ducal regulation sets for the permanent alternative solutions would pay, excluding VAT, EUR 2 per invoice for the first 20 over the cap, EUR 3 for the next 30, EUR 4 for the next 50 and EUR 5 beyond, with received invoices counted the same way.
Last change recorded 18 September 2026. All updates