E-Invoicing in Luxembourg – Current Status and Need for Action*

Background

The digitalisation of invoicing processes in Luxembourg continues to progress.

Having already become mandatory for public sector contracting authorities, the planned extension to the B2B sector means that, in the coming years, many companies will face a significant change to their invoicing and accounting processes.

Current Status

On 17 July 2026, the Luxembourg government adopted the corresponding draft law No. 8815, which is currently going through the parliamentary legislative process.

Accordingly, the phased introduction is planned as follows:

1 January 2028          
All companies established in Luxembourg must be able to receive and process compliant electronic invoices.

1 July 2028                
Large and medium-sized companies exceeding at least two of the three relevant size criteria must issue and transmit electronic invoices to domestic B2B/B2G customers.

1 January 2029          
Extension of the obligation to issue and transmit electronic invoices to all remaining companies.

What Is Meant by an E-Invoice?

An e-invoice is more than a PDF sent by e-mail. Rather, it refers to a structured, machine-readable file (XML) that enables automated processing.

In Luxembourg, the already existing Peppol network is intended to be used as the central technical infrastructure for transmitting this file.

Companies will therefore need to connect their accounting or invoicing systems accordingly, or use a service provider that establishes the connection to the Peppol network.

For companies with a very low invoice volume, as well as for the transitional phase, the draft law provides for alternative technical solutions. The details of this are to be set out in particular by a grand-ducal regulation yet to be issued.

What Should You Do Already Now?

Even though the obligation to issue and receive electronic invoices is currently still subject to the legislative process, we recommend not waiting until shortly before the deadline to make the transition.

In particular, you should:

1. Check which of your company’s invoice flows will be affected; (cross-border incoming/outgoing invoices are not affected for the time being, but must also be exchanged as electronic invoices by 1 July 2030 at the latest.)
2. Check whether your current accounting or invoicing software can generate and receive structured e-invoices;
3. Clarify with your software provider whether a Peppol connection is planned or already available;
4. Reconcile your customer and supplier data, in particular VAT and other identification numbers;

(this data is validated automatically, and invoices with erroneous fields are rejected)

• Review the processes for incoming invoices, outgoing invoices, credit notes and archiving;
• If applicable, select a suitable e-invoicing/Peppol service provider at an early stage.

Early preparation makes it possible to carry out the necessary technical adjustments calmly, select suitable solutions and align the transition with your company’s own operational needs.

As the introduction of the obligation to issue and receive electronic invoices is based on the EU directive ViDA (VAT in the Digital Age), which must be mandatorily implemented by the member states, an adjustment of your processes is definitely necessary.

Conclusion

In our assessment, the introduction of e-invoicing should not primarily be understood as an additional burden. Rather, it offers the opportunity to sustainably optimise your invoicing and accounting processes.

Please also feel free to take advantage of the possibility of having the costs of introducing the relevant software subsidised; suitable programmes available for this include, for example, „Fit 4 Digital“ or the „SME Package – Digital“.

The subsidy should, if applicable, be applied for before the start of the project or the advisory engagement. The specific requirements must be reviewed on a case-by-case basis.

We would be happy to support you with any further questions and with the analysis of the processes to be adapted.

As of 03 September 2026, subject to changes in the further legislative and regulatory process.

* Disclaimer: Please note that this document constitutes general client information only. In particular, it does not constitute tax, legal or other advice. Furthermore, this general client information does not replace a detailed analysis of the specific facts of your case. Should you wish to obtain such an analysis, please do not hesitate to contact us.

 © 2026 LUDWIG & MALDENER S.à r.l. Experts Comptables | Fiduciaire – All rights reserved