Luxembourg e-Invoicing Guide

Luxembourg mandates electronic invoicing for B2G transactions. The law of 16 May 2019 transposed Directive 2014/55/EU, obliging public sector bodies to receive and process compliant e-invoices, and an amending law of 13 December 2021 made issuing e-invoices mandatory for their suppliers. The rollout was phased by company size and has been fully in force since 18 March 2023, so every business invoicing the Luxembourg public sector must now send structured e-invoices.

There is no general B2B or B2C mandate in force yet. Electronic invoicing between private parties is voluntary and depends on the buyer accepting the format. That position is set to change: the government council approved a draft bill on 17 July 2026 extending the obligation to domestic commercial transactions between businesses established in Luxembourg. The bill amends the law of 16 May 2019 and the amended VAT law of 12 February 1979 to transpose Article 1 of Council Directive (EU) 2025/516 of 11 March 2025 , which amends Directive 2006/112/EC as regards VAT rules for the digital age and makes e-invoicing and digital reporting mandatory for intra-EU B2B transactions from 1 July 2030. The bill has yet to pass through parliament, and no implementation dates have been set.

Central public bodies have been required to receive e-invoices since 18 April 2019, with sub-central bodies following on 18 April 2020. The supplier-side obligation arrived in three waves under the law of 13 December 2021: large companies from 18 May 2022, medium-sized companies from 18 October 2022, and small or newly established businesses from 18 March 2023. Since that final wave, the B2G mandate covers suppliers of every size. The next fixed date is 1 October 2026, when XRechnung versions below 3.0 stop being accepted. Attention then turns to B2B: the draft bill approved by the government council on 17 July 2026 extends the obligation to domestic transactions between Luxembourg-established businesses, but it has yet to pass through parliament and no implementation dates have been set.

Any business issuing invoices to Luxembourg public sector entities, regardless of size or country of establishment, must send structured e-invoices, whatever the invoice amount and whatever procedure was used to award the contract. A narrow set of derogations applies: the obligation does not cover public procurement contracts entered into for development cooperation, by diplomatic missions or consulates, as part of Luxembourg's participation in international fairs and exhibitions held abroad, or as part of State visits, official visits or working trips abroad.

Invoices have to comply with the European standard EN 16931. Guichet.lu accepts Peppol BIS Billing 3.0 in UBL syntax and XRechnung 3.0.1 in either UBL or UN/CEFACT CII syntax, for invoices and credit notes alike. From 1 October 2026 the older XRechnung 2.2.0 and 2.3.1 versions are no longer accepted, having been obsolete since 2023 and 2024 respectively. An XRechnung invoice can travel over the Peppol network, but it must be adjusted to carry the Peppol identifiers of the sender and the recipient. Ordinary PDF invoices and paper invoices no longer satisfy the B2G obligation.

Outside the public sector the requirements are lighter for now. B2B e-invoicing is voluntary, and businesses may continue to use paper invoices, PDF invoices backed by an electronic signature or a reliable audit trail, or structured e-invoices exchanged via EDI, provided the buyer agrees and general VAT invoicing rules on content, authenticity, and integrity are met. Businesses that keep their accounts under the Luxembourg Standard Chart of Accounts must also be able to produce a FAIA file, Luxembourg's SAF-T audit file, when the VAT authority requests one. Invoices must be archived for 10 years from the end of the year of issue.

Luxembourg uses a decentralised Peppol model with no central government clearance platform. Suppliers connect through a Peppol Access Point of their choice and send invoices across the network to the receiving public body. The Ministry for Digitalisation publishes an open list of the public sector bodies reachable via Peppol , which named 793 organisations on 20 July 2026, alongside technical guidance on the national eFacturation portal . Invoices are not validated or approved by the tax authority before delivery. A draft grand-ducal regulation endorsed alongside the July 2026 B2B bill will designate a common delivery network, with alternative technical solutions, for issuing, transmitting and receiving e-invoices, so that trading partners are not forced onto separate, non-interoperable systems.

Businesses without a Peppol solution can instead submit invoices manually through Guichet.lu , either by entering the invoice data into an online form that generates the e-invoice or by uploading a valid Peppol BIS Billing 3.0 or XRechnung 3.0.1 file. Public sector bodies receive over their own Peppol access point or, failing that, the CTIE government access point, which ministries and State administrations must always use. The Ministry for Digitalisation coordinates the B2G programme, while VAT matters sit with the Administration de l'enregistrement, des domaines et de la TVA (AED). A supplier already sending Peppol BIS Billing 3.0 invoices elsewhere in Europe can usually reach Luxembourg public bodies without new infrastructure.

Luxembourg has no dedicated penalty regime for e-invoicing. The practical sanction for B2G non-compliance is rejection: a file that does not meet the European standard is rejected during back-office processing and never reaches the recipient public body, so payment is delayed until a compliant invoice or credit note is issued. General VAT sanctions still apply, so incorrect or missing invoices and failures to meet record-keeping or FAIA obligations can attract fines from the AED under ordinary VAT law.