New invoicing obligations
3 August 2026
Input newsletter
At a glance
Businesses must act to be able to issue and receive e-invoices for Luxembourg domestic B2B transactions as from 1 January 2028, by assessing their current invoicing processes, upgrading their IT and ERP systems where necessary, and ensuring compliance with the forthcoming legal and technical requirements.
A closer look
On 30 July, the Luxembourg government has lodged with the Chamber of Deputy a draft bill introducing mandatory e-invoicing for supplies of goods and services between taxable persons established in Luxembourg [i.e., domestic business-to-business (B2B) transactions]1.
By doing so, Luxembourg is not acting in isolation or ahead of market practice. E-invoicing is becoming increasingly common across the world2. For example, Belgium has introduced e-invoices since 1 January 2026. France will do the same from September 2026, Germany from 1 January 2027, Ireland and the UK in 2028 and 2029 respectively. The initiative also aligns with the EU VAT in the Digital Age (ViDA) Directive, which will require e-invoicing for EU cross-border B2B transactions from 1 July 2030. In this respect, the introduction of the domestic B2B e-invoices could be considered as an opportunity for Luxembourg businesses to prepare for future EU requirements.
The key elements of the draft bill are outlined below.
Scope of the obligation
An e-invoice must be issued between businesses established in Luxembourg (i.e. issuer and beneficiary) for transactions which are deemed to take place in Luxembourg under Luxembourg VAT law and for which an invoice must be issued.
This approach ensures consistency with existing VAT rules and confirms that no e-invoices should be issued for exempt financial, fund management, and insurance services. This is particularly significant in the Luxembourg context.
Definition and technical standard
The draft bill does not introduce a separate definition of e-invoices. Instead, it refers to the European standard adopted under Directive 2014/55 of 16 April 2014 on e-invoicing in public procurement.
Under this framework, an e-invoice is “an invoice that has been issued, transmitted and received in a structured electronic format which allows for its automatic and electronic processing.” This means that invoices must comply with standard EN 16931 of the European Committee for Standardization. The standard has been updated to align with ViDA requirements. These changes have been approved by the European Committee for Standardization on 23 October 2025, and the Luxembourg version has been published by the Luxembourg Institute of Standardization in April 20263.
Transmission of e-invoices
The e-invoices must be transmitted and received via one single network. The draft bill provides the conditions this network must meet without naming it. However, it is likely that it would be the Pan-European Public Procurement On-Line network (PEPPOL). This would be consistent with the existing obligation to use PEPPOL for B2G e-invoicing in Luxembourg. It also reflects the broader use of PEPPOL across the EU (for example in Belgium) and internationally. By relying on one network, the draft bill aims to ensure compliance with the ViDA Directive requirements, namely security, non-repudiation, integrity, confidentiality and interoperability at both national and international levels. In other words, there should be no duplication of rules and efforts between the national and EU levels.
Required invoice information
The invoices must include essential elements that are close (but not identical) to those currently required by the Luxembourg VAT law. This includes information identifying the supplier, the client, the supply, the price and the necessary information to determine the VAT due (e.g. VAT rate). Certain additional elements may also be required, such as contract references and payment instructions.
Phased implementation timeline
The obligation to issue e-invoices will be introduced gradually, depending on the size of the business:
- Larger businesses and medium-sized businesses4: From 1 July 2028.
- Small businesses: From 1 January 20295.
However, this phased timeline applies only to the obligation to issue an e-invoice.
When it comes to receiving e-invoices, all businesses should be ready by 1 January 2028.
Smaller businesses may therefore need to receive e-invoices before they are required to issue them. For example, they may receive e-invoices from larger suppliers that must comply from 1 July 2028 for their electricity or mobile phones bills for instance.
Alternative methods during the transition
To support smaller businesses complying during this transition, certain alternative methods to the unique network will be available under specific conditions. A grand ducal decree will be issued to determine these alternative solutions and the conditions under which they could be used including the thresholds under which these alternative methods could be used.
Once these thresholds are exceeded, a service fee per invoice will be due6.
Why businesses should prepare now
This draft bill marks an important step in the implementation of e-invoicing in Luxembourg. As the rules are designed with ViDA requirements in mind, early preparation may help businesses avoid duplicated implementation efforts when EU cross-border e-invoicing rules apply.
The Deloitte Luxembourg Indirect Tax Team remains at your disposal to discuss the potential impacts on your organization.
If you require further information or guidance on the next steps to take, our specialists are available to help!
Footnotes
2 https://www.deloitte.com/global/en/services/tax/services/gx-tax-atlas-digital-services-tax.html
4 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.
5 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.
6 €2 per invoice for the twenty invoices above the thresholds, €3 per invoice for each of the next thirty invoices, €4 for each of the next fifty invoices, and €5 for each of the following invoices, amounts ex VAT.
