What has Luxembourg proposed?
Luxembourg submitted Draft Law No. 8815 to Parliament on 30 July 2026, proposing mandatory structured e-invoicing for qualifying domestic transactions between businesses established in Luxembourg.
The proposal would require affected businesses to exchange machine-processable invoices rather than relying on paper, PDF or other unstructured invoice formats. The draft must still complete the parliamentary process before becoming law, and some technical requirements will be confirmed through implementing regulations.
When will Luxembourg's mandatory B2B e-invoicing rules take effect?
The legislation would generally apply from 1 January 2028, when in-scope businesses would need to receive and process compliant electronic invoices.
Mandatory issuance would be phased as follows:
- 1 July 2028: Businesses exceeding at least two of the specified thresholds, based on their 2026 balance-sheet, turnover and average full-time employee figures.
- 1 January 2029: Remaining in-scope businesses, including those unable to provide the information required to determine which issuance phase applies.
Luxembourg e-invoicing implementation timeline
What will Luxembourg's mandatory B2B e-invoicing rules mean for businesses?
The proposed mandate would generally apply where:
- the invoice issuer and recipient are established in Luxembourg;
- the transaction is taxable in Luxembourg;
- Luxembourg VAT law requires an invoice; and
- the transaction is not covered by the relevant intra-Community reporting provisions.
The proposal would therefore not apply automatically to every invoice exchanged between two Luxembourg entities. It also contains specific exclusions for certain transactions.
What are Luxembourg's structured e-invoicing requirements?
Invoices would need to use a structured electronic format that supports automated processing and complies with the applicable European e-invoicing standard and an authorized syntax.
A PDF, Word document or invoice image would not qualify as a compliant e-invoice on its own.
Which businesses must receive and process e-invoices?
From 1 January 2028, in-scope recipients would need to receive and process compliant e-invoices from Luxembourg-established issuers.
Processing would include:
- validating the invoice;
- routing it through the appropriate internal workflow;
- disputing or rejecting it where necessary;
- approving and paying it.
The receipt obligation could also apply to compliant invoices issued voluntarily by Luxembourg suppliers that are not yet subject to mandatory issuance.
When must businesses issue compliant e-invoices?
Businesses exceeding at least two of the following thresholds, based on their figures at the closing date of the 2026 balance sheet, would need to issue and transmit compliant e-invoices no later than 1 July 2028:
- €7.5 million balance-sheet total;
- €15 million net turnover; or
- 50 average full-time employees.
Businesses that do not exceed at least two of these thresholds would need to comply no later than 1 January 2029.
Which network will Luxembourg use for e-invoicing?
The proposal would require invoices to be exchanged through a designated common delivery network.
The Luxembourg government has indicated that it intends to reuse Peppol, which is already used for public-sector e-invoicing. However, the final network designation, local identifiers and technical parameters will be confirmed through secondary regulation.
What should businesses do next?
Businesses with Luxembourg operations should begin assessing:
- whether their transactions fall within scope;
- which issuance phase applies based on their 2026 balance-sheet, turnover and average full-time employee figures;
- current domestic invoice volumes.
Larger businesses would have approximately six months between the proposed inbound requirement on 1 January 2028 and the first outbound deadline on 1 July 2028.
Although the proposal remains in draft, early preparation will help affected businesses understand their implementation requirements and prepare for the proposed deadlines.
