The essentials in 30 seconds: Bill No. 8815, tabled on 30 July 2026, extends the requirement for electronic invoicing to domestic B2B transactions in Luxembourg (between Luxembourgish businesses). If the bill is passed, the receipt of structured electronic invoices will become mandatory from 1 January 2028, whilst the issuing of such invoices will be phased in between 1 July 2028 (for large companies) and 1 January 2029 (for other companies). Invoices must comply with the European standard EN 16931 and be transmitted via a common delivery network. Companies are advised to start preparing now to ensure technical compatibility.

What is the B2B e-invoicing reform in Luxembourg?

Luxembourg is set to take a new step forward in the digitalisation of commercial transactions. With the tabling of Bill No. 8815 on 30 July 2026, the government intends to extend the requirement for electronic invoicing to domestic transactions between businesses established in Luxembourg. If the bill is passed, the reform will therefore no longer apply solely to dealings with the public sector, but will also cover domestic B2B transactions.

A requirement already in place in the public sector

At present, electronic invoicing is already mandatory in dealings between businesses and public sector bodies — ministries, government departments and local authorities — in the context of public procurement or concession contracts. This requirement came into force gradually between May 2022 and March 2023.

Bill No. 8815 is a continuation of this trend: extending this approach to the private sector, for domestic transactions between businesses.

Why this reform?

This reform has four main objectives:

• To combat VAT fraud: structured electronic invoicing enables better monitoring of tax returns and reduces invoicing discrepancies.
• To accelerate the modernisation of businesses by encouraging the digitisation of administrative and accounting processes and the use of integrated management tools.
• To streamline invoice processing and, in the long term, reduce certain administrative and payment lead times through the standardisation and automation of data exchanges.
• To align with the European framework: the European Union is moving towards the gradual harmonisation of electronic invoicing, with a deadline already set for 1 July 2030 for intra-Community B2B transactions.

When does the requirement for electronic invoicing come into force?

The requirement is set to come into force gradually from 1 January 2028, in accordance with three deadlines.

Deadline	Requirement	Businesses affected
1 January 2028	Receipt and processing of electronic invoices	All affected businesses
1 July 2028 (at the latest)	Issuing electronic invoices	Businesses exceeding at least two of the three thresholds: balance sheet total of €7.5 million, net turnover of €15 million, average workforce of 50 people
1 January 2029 (at the latest)	Issuing electronic invoices	All other affected businesses

The balance sheet at the end of the 2026 financial year would be taken into account when assessing these thresholds.

Which businesses are affected?

In principle, this would apply to businesses established in Luxembourg that issue invoices to other businesses also established in Luxembourg, where the transaction is taxable in Luxembourg and subject to an invoicing obligation under VAT rules.

In principle, the following would not be affected:

• cross-border transactions;
• sales to private individuals;
• certain exempt transactions, particularly in the financial and insurance sectors.

Point to note — foreign companies with a Luxembourg VAT number: simply having a Luxembourg VAT number is not sufficient to bring a company within the scope of the reform. Without a permanent establishment in Luxembourg, it would, in principle, not be considered to be established in Luxembourg for the purposes of these new national B2B obligations.

What is a compliant electronic invoice?

A compliant electronic invoice is not simply a PDF sent by email. It must be drawn up in a structured format, in accordance with the European standard EN 16931, so that it can be read and processed automatically by accounting software. In practice, this should be an XML file in UBL format.

In practical terms, an invoice created solely using Word, Excel or in the form of an unstructured PDF will no longer be sufficient. A PDF may still accompany the transmission for human-readable purposes, but it will not, on its own, constitute a valid electronic invoice. Only a structured electronic invoice will be compliant.

How does Peppol work in Luxembourg?

Businesses will be required to use the common delivery network provided for under the bill to issue, transmit and receive their electronic invoices. In practice, these exchanges should be routed via the Peppol network.

To use this network, each business will need to go via an access point, i.e. a technical access point connected to Peppol. The invoice will be sent from the supplier’s access point to the customer’s, and then integrated directly into the customer’s accounting or management software.

The first stage of the reform will focus on the receipt of invoices: businesses will first need to be able to receive structured invoices, before gradually being required to issue them themselves in this format.

How can you start preparing now?

Even though the B2B reform has not yet been definitively adopted, it is advisable to start planning ahead now:

1. Check that your organisation is capable of receiving structured electronic invoices.
2. Ensure that your invoicing and/or accounting software is compatible with the required format.
3. Identify the necessary changes to internal processes.
4. Eventually, replace methods relying on Word, Excel or simple PDFs with a compliant solution.

What solutions are available?

At In Extenso Belux, we offer several solutions tailored to your needs:

• InexDemat — An online portal for digitising accounting documents and sending them quickly to your accountant. Includes a Peppol access point for receiving electronic invoices, as well as an invoicing module for creating and sending invoices via Peppol. Integrated with Sage Bob accounting software.
• Falco — A solution similar to InexDemat, particularly suitable when accounts are already managed in Horus, to which it is linked.
• Odoo — An integrated management solution (accounting, invoicing, sales, purchasing, stock, CRM, human resources, e-commerce) that can play a role in the implementation of electronic invoicing, both for issuing and receiving compliant invoices.

What role will MyGuichet.lu play?

In principle, businesses will be required to use the shared delivery network. However, alternative fallback solutions may remain in place for businesses that are not yet ready to use this network or that process a very limited volume of invoices.

In line with this, MyGuichet.lu could continue to play a simpler, more manual and less automated role, possibly free of charge up to certain limits yet to be set by Grand Ducal regulation. The preferred solution, however, remains clearly Peppol, particularly as it can be integrated with platforms offering broader digitisation and management capabilities.

Are there any penalties provided for?

At this stage, the draft does not provide for any specific general penalty in the event of failure to meet deadlines. However, there may be other practical consequences under VAT rules or in relation to the processing of invoices.

What financial support is available for SMEs?

Existing schemes, primarily aimed at SMEs, provide funding for their digital transition — provided that the application is submitted before any technical work begins or a solution is selected.

• Investment grants: between 10 and 20 per cent of digital or hardware investments.
• SME Packages – Digital: up to 70 per cent of the costs associated with a digitalisation project, generally amounting to between €3,000 and €25,000 excluding VAT.
• Fit4Digital: digital maturity assessment and action plan.
• Training co-funding: support covering 15% of certain training hours and costs.

Getting support

Your contact at In Extenso Belux is on hand to assist you with:

• checking the compatibility of your accounting software;
• identifying any necessary adjustments to your processes;
• providing an update on the support available;
• determining the solution best suited to your situation.

In conclusion

Electronic invoicing will gradually become the new norm in Luxembourg. Beyond being a future legal requirement, it represents, above all, a practical transformation in the way invoices are issued, received and processed. For the businesses concerned, the best course of action is to plan ahead now: review existing systems, ensure the right technical choices are made and, where necessary, make use of the support available to ensure a smooth transition.