Tax, Accounting and Reporting: VAT and digital compliance

Mandatory e‑invoicing in Luxembourg: preparing for 2028

Luxembourg is extending mandatory structured electronic invoicing to domestic B2B transactions. Under draft bill no. 8815, compliant e‑invoices exchanged through Peppol will become the only legally valid invoicing format for in‑scope transactions from 2028. Our VAT and digital compliance specialists can support you from the initial scope assessment through to go‑live.

Key dates at a glance

Implementing the necessary processes can take time, usually several months. Complying with the electronic invoicing rules will be a project that will have to be thought and planned carefully.

Luxembourg - Domestic B2B e-invoicing

Invoices exchanged between businesses established in Luxembourg must be issued as compliant structured e-invoices through Peppol. Paper and PDF invoices will no longer be legally valid for in-scope transactions.

European Union - ViDA: cross-border e-invoicing and digital reporting

The EU directive has been adopted and will be transposed into Luxembourg law. E-invoicing will become the default for intra-EU B2B transactions, with transaction-level digital reporting to the tax authorities.

How we can help

A structured approach, from scope assessment to VAT compliance

Each step delivers a clear output. You can engage us for the full programme or for specific steps, depending on your needs.

Related services to consider

E-invoicing impacts your data, contracts and systems. Addressing the following topics within the same project can generate efficiencies and avoid rework. Select a topic for more detail. This list is not exhaustive, the step number indicates where each topic fits in our approach.

Missing or inaccurate VAT numbers and Peppol identifiers may lead to rejected invoices and payment delays. Cleaning your master data also improves the quality of your VAT returns and payment processes.

Should you be interested in various solutions, we can support you in drafting the requirements, building the evaluation grid, organising demo and reviewing the offers. This can be done whether you use SAP, Microsoft Dynamics 365, Oracle, Sage or a local accounting package. A solution selected for Luxembourg only may not cover archiving, other jurisdictions or ViDA reporting; assessing this upfront can avoid a second selection process.

E-invoices and return messages must be retained for ten years, with their integrity and accessibility guaranteed for the tax authorities. Defining the storage approach at the design stage avoids costly migrations later.

Existing contracts may still refer to paper or PDF invoices, and self-billing requires a prior agreement and an acceptance procedure. Updating your contractual documentation now reduces the risk of disputes over the valid invoice.

From July 2030, intra-EU transactions will need to be reported on a transaction-by-transaction basis. Designing a single target model now avoids duplicating system changes. About ViDA

A successful go-live depends on your suppliers and customers being reachable through Peppol. A structured communication plan limits rejected and manual invoices in the first months.

Rejections and return messages change the day-to-day work of AP/AR teams. Training on the target process helps avoid errors and backlogs at go-live.

Assess your e-invoicing readiness with PwC

Whether you issue invoices, receive them or both, an early assessment leaves time to plan IT changes, onboard your business partners and test before the applicable deadline.

Timeline

A phased implementation based on company size

All in-scope businesses* must be able to receive e-invoices from 1 January 2028. The obligation to issue e-invoices applies from 1 July 2028 or 1 January 2029, depending on company size.

^{*This is the current terminology under the draft law. However, the reference to the entities in scope for related E-invoicing requirements can potentially evolve and we will properly update the information, for your benefit.}

1 January 2028

Reception – all businesses

Obligation to receive for all in-scope businesses

All in-scope recipients, regardless of size, must be able to receive and process compliant e-invoices. Businesses not yet connected to Peppol may temporarily use a MyGuichet.lu professional space, with no volume limit, until 30 June 2028 (large and medium-sized enterprises) or 31 December 2028 (small enterprises).

1 July 2028

Issuance – large and medium-sized enterprises

Obligation to issue for large and medium-sized enterprises

Large and medium-sized enterprises must issue compliant e-invoices for in-scope domestic B2B transactions from this date.

1 January 2029

Issuance – small enterprises

Obligation to issue for all other businesses

Small enterprises, and businesses unable to provide their 2026 figures, must issue compliant e-invoices from this date.

How is company size determined?

Company size is assessed once, at the 2026 balance sheet date. A business is considered large or medium-sized if it exceeds at least two of the following three thresholds:

€7.5m balance-sheet total
€15m net turnover
50 full-time employees on average

The assessment is performed entity by entity; two Luxembourg entities of the same group may therefore be subject to different deadlines.

Is your business in scope?

Which solution is right for your business?

Peppol is the standard delivery network. MyGuichet.lu, the government portal, offers free manual alternatives, available only during a transition period or for very limited volumes.

Peppol, through a service provider

Your system issues and receives compliant e-invoices automatically, with no volume limit. This is the standard solution for most businesses.

Receive from 1 January 2028. Issue from 1 July 2028 (large and medium-sized enterprises) or 1 January 2029 (other businesses). Cost: according to your provider's pricing.

MyGuichet.lu, low-volume alternative

The de minimis alternative may be appropriate. Invoices are issued individually through an online form and received in a certified MyGuichet.lu professional space. This alternative has no end date.

Free of charge up to 75 invoices issued and 150 received per year. Above these thresholds, a usage fee applies per additional invoice (see below).

Usage fee above the thresholds, per invoice issued or received (excluding VAT): EUR 2 for the first 20, EUR 3 for the next 30, EUR 4 for the next 50 and EUR 5 thereafter. Thresholds apply separately to invoices issued and received.

MyGuichet.lu upload form

Rather than re-entering each invoice, you upload the compliant e-invoice generated by your software and MyGuichet.lu transmits it. This is suitable for low volumes, or while you select a Peppol service provider.

Same threshold: free of charge up to 75 invoices issued per year; a usage fee applies above.

MyGuichet.lu professional space, transition period

You may receive e-invoices and related return messages in the professional space while completing your Peppol connection. During the transition period, no volume limit or fee applies.

Until 30 June 2028 (large and medium-sized enterprises) or 31 December 2028 (small enterprises, or businesses unable to provide 2026 figures). Apply by 1 December 2027 at the latest; the online procedure will open by 1 October 2027.

^{Usage fee above the thresholds, per invoice issued or received (excluding VAT): EUR 2 for the first 20, EUR 3 for the next 30, EUR 4 for the next 50 and EUR 5 thereafter. Thresholds apply separately to invoices issued and received.}

^{Sources: Draft bill no. 8815 and draft Grand-Ducal Regulation on the common delivery network and alternative technical solutions. Both texts remain subject to change.}

From domestic e-invoicing to ViDA

Designing your 2028 set-up with EU digital reporting in mind will help you avoid duplicating efforts.

From 1 July 2030, the EU's VAT in the Digital Age (ViDA) package requires intra-EU transactions to be reported to the tax authorities on a transaction-by-transaction basis, based on e-invoices. The Luxembourg draft bill is explicitly intended to prepare businesses for this next step.

Until then, businesses will operate two invoicing regimes in parallel: structured e-invoices for domestic B2B transactions and the current rules for cross-border transactions.

Read our flash news on ViDA

Belgium	Mandatory B2B e-invoicing since 1 January 2026
France	Generalised by 1 September 2027
Luxembourg	Reception from 1 January 2028, issuance by 1 January 2029
Germany	Generalised by 1 January 2028
EU-wide	ViDA digital reporting for intra-EU transactions from 1 July 2030

Frequently asked questions

Yes, as an attachment. However, only the compliant e-invoice constitutes the invoice. All mentions required under VAT and company law must therefore be included in the structured data, not only in the PDF.

Not for in-scope invoices. The draft bill removes the requirement for the recipient's acceptance, and recipients must receive and process compliant e-invoices in the same way as any other invoice.

Your own exempt supplies are generally excluded. However, as a business established in Luxembourg, you are likely to receive in-scope invoices from Luxembourg suppliers and will therefore need to be able to receive e-invoices from 1 January 2028.

Not as an issuer, since supplies by businesses not established in Luxembourg are excluded. However, your Luxembourg customers will change the way they receive invoices, and cross-border flows will be affected by ViDA from 2030.

Yes. Self-billed compliant e-invoices remain possible, provided that a prior agreement exists between the parties and each invoice is subject to an acceptance procedure.

No. Draft bill no. 8815 and its implementing regulation are still subject to the legislative process, and dates, thresholds and technical rules may change. The direction is nevertheless clear, and the lead time required for ERP and supplier changes makes an early start advisable.