The government approved a bill on 17 July that would extend mandatory electronic invoicing beyond public contracts and concession agreements to transactions between businesses established in Luxembourg.
All companies would have to be able to receive electronic invoices from 1 January 2028, according to the Chamber of Commerce. Large and medium-sized businesses would have to issue them from 1 July 2028, with the requirement extended to other companies from 1 January 2029.
The government also approved a proposed Grand-Ducal regulation establishing a common network and alternative ways of sending and receiving invoices. “The aim is to avoid invoice issuers and recipients having to deploy and use separate, non-interoperable technical solutions,” it said.
The proposal would turn a system already used by suppliers to public bodies into a requirement for day-to-day transactions between Luxembourg businesses. Companies would need software capable of exchanging standardised invoice data, while the unpublished legal texts will determine the precise scope, company categories, exceptions and enforcement arrangements.
From voluntary use to compulsion
Luxembourg first required public bodies to accept structured electronic invoices in 2019, but suppliers were not initially obliged to issue them electronically. A 2021 explanatory memorandum said voluntary use had produced no significant change and that electronic invoicing remained almost non-existent in both public- and private-sector transactions.
Parliament subsequently made electronic invoicing compulsory for suppliers billing public bodies, with deadlines phased according to company size. The new proposal would extend that compulsory model to domestic B2B invoices.
The Chamber said the transition would use Peppol, the European network already employed for public-sector invoicing. Almost 1.4 million invoices passed through Peppol in Luxembourg in 2024, while about 800 public bodies and more than 1,400 private entities were using it.
A structured electronic invoice is not simply a PDF sent by email. Its information must be recorded in a standard format that software can read and process automatically.
Changing systems and processes
Companies will have to check whether their accounting software can connect to the network and change how invoices are received, approved and recorded. The 2021 memorandum said the expected gains depended on businesses redesigning parts of their invoicing, payment and contract-management processes.
Sales-Lentz began sending structured electronic invoices in 2022 after adapting its SAP system and overhauling its billing data. The company said monthly invoicing work fell from four or five days to between four and six hours, but described the change as a cross-departmental project rather than a simple software installation.
KPMG Luxembourg had predicted the proposed rollout and Peppol choice before the government decision. “While a phased approach can help SMEs, multiple co-existing mechanisms increase ecosystem complexity and operational burdens,” its specialists wrote.
Receiving and issuing duties would apply differently during the transition according to company size. Businesses and software providers would therefore have to track which counterparties were covered and when their obligations began.
Some Luxembourg groups are already dealing with structured invoices through operations elsewhere in Europe. Germany, Belgium and France have introduced or begun phasing in their own domestic requirements, although those rules do not directly apply to transactions between Luxembourg businesses.
Support before the deadline
The Chamber said electronic invoicing could reduce manual data entry, errors and payment delays. “The gradual timetable gives businesses the time needed to integrate these new tools without disrupting their day-to-day operations,” it said.
It plans information sessions, workshops and guidance for companies choosing an invoicing system. An existing programme offers eligible businesses support covering 70% of software projects costing between €3,000 and €25,000 before VAT.
The Chamber called for the bill to move quickly once it reaches parliament. The government-approved text had not appeared in parliament’s public dossier system by 20 July, and no timetable for committee scrutiny or debate had been announced.
