Further details on new e-invoicing obligations

In our newsletter of 3 August¹ regarding the draft bill introducing mandatory e-invoicing in Luxembourg for supplies of goods and services between taxable persons (B2B transactions) from 2028², we noted that that a Grand-Ducal Decree would be issued to supplement the legislation.

The draft decree is now available³ and serves a twofold purpose. First, it confirms PEPPOL as the network to be used for the issuance, transmission and receipt of e-invoices. Second, it provides details on the alternative methods that may be used in certain circumstances.

PEPPOL

As mentioned in our newsletter of 3 August, the draft bill on mandatory e-invoicing requires the use of a single network for the issuance, transmission and receipt of e-invoices. While the draft bill sets out the conditions that this network must meet, it does not expressly identify it.

In our previous communication, we also indicated that the Pan-European Public Procurement On-Line (PEPPOL) network was the most likely candidate, given its existing use for B2G (business-to-government) e-invoicing in Luxembourg and its growing adoption across the European Union, including in Belgium, as well as in other jurisdictions worldwide.

The Grand-Ducal Decree now confirms that PEPPOL is the designated network.

Relying on a single network helps ensure compliance with the requirements of the ViDA Directive, notably in terms of security, non-repudiation, integrity, confidentiality and interoperability at both national and international levels. This approach should also avoid duplicative requirements and implementation efforts between the Luxembourg and EU frameworks.

Alternative methods

To support smaller businesses, certain alternative methods to the unique network will be available under specific conditions.

Receipt of e-invoices

As a reminder, all businesses must be able to receive e-invoices by 1 January 2028.

As an alternative to the unique network, a certified business space on MyGuichet.lu will be available for receiving e-invoices. This alternative solution will be available only during a transitional period.

Businesses that exceed at least two of the following three criteria based on their 2026 financial year may use this alternative method until 30 June 2028:

a) Balance sheet total: EUR 7 500 000;

b) Net turnover: EUR 15 000 000;

c) Average number of full-time employees: 50.

Businesses that do not exceed at least two of these three criteria may use this alternative method until 31 December 2028⁴.

This service will be provided free of charge for businesses receiving up to 150 e-invoices. Beyond this threshold, the following fees will apply (excluding VAT):

• €2 per invoice for the next 20 invoices
• €3 per invoice for the following 30 invoices
• €4 per invoice for the next 50 invoices
• €5 per invoice for each additional invoice thereafter

Issuance and transmission of e-invoices

As a reminder, the obligation to issue and transmit e-invoices will be introduced gradually, depending on the size of the business:

• Larger businesses and medium-sized businesses⁵: From 1 July 2028.
• Small businesses: From 1 January 2029⁶.

For the issuance and transmission of e-voices, two alternative methods will be available without any time limitation.

The first options is an online form available on MyGuichet.lu. Businesses will be able to manually enter all invoices details into the form and submit it, generating a compliant electronic invoice.

The second option is also an online form that enables businesses to transmit an e-invoice that has already been created in a compliant electronic format to the recipient.

These alternative methods may be used free of charge for up to 75 e-invoices issued. Once this threshold is exceeded, the service fees described above will apply.

Comments

The commentary of articles of the e-invoice draft bill emphasizes that these alternative methods must be considered as backup or stopgap solutions that do not offer the advantages of the PEPPOL network in terms of efficiency, and end-to-end digitization, coverage of all the invoicing and purchasing processes concerned. This explains why they are only offered on a temporary basis or only in exceptional cases.

The commentary accompanying the draft e-invoicing bill emphasizes that these alternative methods should be viewed as backup or transitional solutions. They do not offer the same benefits as the PEPPOL network in terms of efficiency, end-to-end digitalization, or integration across invoicing and procurement processes. This explains why they are available only for a limited period or in specific circumstances.

In this regard, it is worth noting that, in Belgium, the PEPPOL network is the only available solution and is already used by more than two millions of participants⁷.

Our views

This Grand Ducal Decree marks an important milestone in the implementation of e-invoicing in Luxembourg.

As the proposed framework has been designed with the EU's VAT in the Digital Age (ViDA) initiative in mind, businesses that start preparing early may be better positioned to streamline compliance and avoid duplicative implementation efforts when EU-wide cross-border e-invoicing requirements come into effect.

The Deloitte Luxembourg Indirect Tax Team remains at your disposal to discuss the potential implications for your organization.

If you would like to assess the impact of these changes or discuss the next steps, our specialists are ready to assist.

Footnotes

¹ New invoicing obligations | Deloitte Luxembourg | Input VAT | News

² 20260730_Depot.pdf

³ eli-dl-pr-2026-232-doc-dprgd-1-fr-pdf.pdf

⁴ This also applies to businesses that are unable to provide the financial data required to assess at least one of the three criteria for the 2026 financial year.

⁵ Those that do not exceed at the date of the closure of the 2026 annual accounts two of the three following criteria: 25 million of balance sheet, € 250 million of net turnover or 250 full time employees.

⁶ Those that do not exceed at the date of the closure of the 2026 annual accounts two of the three following criteria: 7.5 million of balance sheet, € 15 million of net turnover or 50 full time employees; and those which cannot provide at least one of these three criteria for the year 2026.

⁷ Peppol statistics 2026: 4.4M participants, Belgium leads with 2M | e-invoice.be