Electronic invoicing is no longer a public-procurement topic only. On 17 July 2026 the Government Council approved a draft law extending the electronic invoicing obligation to transactions between companies established in Luxembourg. For most Luxembourg companies this means an IT and accounting project that has to be completed before 2028.
Here is what already applies, what has just been decided, what still needs to be confirmed by Parliament, and above all what is worth doing right now.
I. What is already mandatory: invoices sent to the public sector
The starting point is the law of 16 May 2019 on electronic invoicing in public procurement and concession contracts, as amended by the law of 13 December 2021. Since 18 March 2023, every company, Luxembourg or foreign, invoicing a public-sector body must issue a compliant electronic invoice, whatever the amount and whatever the procurement procedure used.
The Grand-Ducal Regulation of 13 December 2021 designated the common delivery network to be used: Peppol. An electronic invoice within the meaning of the law is therefore a structured file, in XML format, transmitted through an interoperable channel, and not a PDF sent by email.
For companies that only occasionally invoice the public sector, the MyGuichet.lu portal offers alternative technical solutions allowing a compliant invoice to be entered or transmitted manually, without investing in dedicated software.
One operational detail not to be overlooked: support for versions 2.2 and 2.3.1 of the XRechnung format ends on 1 October 2026. Companies still using these versions need to plan an upgrade.
II. What the government decided on 17 July 2026
Meeting on 17 July 2026, the Government Council approved a draft law amending two texts: the law of 16 May 2019 on electronic invoicing and the amended law of 12 February 1979 on value added tax. The stated objective is to extend the electronic invoicing obligation, today limited to public procurement and concession contracts, to domestic commercial transactions between companies established in Luxembourg.
The draft transposes Article 1 of Council Directive (EU) 2025/516 of 11 March 2025, which adapts VAT rules to the digital age. Luxembourg is therefore not moving alone: it is aligning its timetable with a European process already under way.
On the same day, the Council endorsed a draft Grand-Ducal Regulation setting the common delivery network and the alternative technical solutions made available. The stated intention is to avoid invoice senders and recipients being forced to deploy separate, non-interoperable solutions.
One point deserves emphasis, because it changes how these announcements should be read: this is a draft law. The text still has to go through the legislative process, collect the required opinions and be voted on. The dates below are therefore announced deployment dates, not yet definitive legal dates.
III. The announced timetable: reception first, issuance next
The rollout would take place in stages, distinguishing the obligation to receive electronic invoices from the obligation to issue them.
| Deadline | What becomes mandatory | Companies concerned |
|---|---|---|
| 1 January 2028 | Receiving electronic invoices | All companies |
| 1 July 2028 | Issuing electronic invoices | Large and medium-sized companies |
| 1 January 2029 | Issuing electronic invoices | All other companies, in particular the smallest structures |
This sequence has a practical consequence that is often misunderstood: from 1 January 2028, a small business with no obligation to issue yet will nonetheless have to be able to receive an electronic invoice from its suppliers. That is the first step, and the least expensive one to take.
IV. How an electronic invoice is actually issued
There are three ways of connecting to the Peppol network, and the choice mainly depends on the size of the business and its level of digitalisation.
- Rent a Peppol access point from a specialised provider. This is the fastest and most common solution for SMEs.
- Set up your own Peppol access point. This option becomes relevant above a certain size, when the company has an in-house IT team.
- Use invoicing software or an ERP that natively issues compliant invoices via Peppol. Many tools now include this function by default.
In all three cases the question is not purely technical. It touches the chart of accounts, the quality of customer and supplier data, and the way incoming invoices are checked, reconciled and archived.
V. What an electronic invoice is not
The most frequent confusion is to believe that a PDF sent by email is an electronic invoice. It is not, in regulatory terms. A compliant electronic invoice is a structured, machine-readable document, issued in a standardised format and transmitted through an interoperable network.
This distinction has direct consequences: data must be correct from the moment of issuance, because downstream manual re-entry disappears. An incorrect VAT number, a missing purchase-order reference or an inaccurate Peppol identifier will block the invoice instead of being quietly corrected by an accountant.
VI. What is worth doing now
The 2028 deadline looks distant, but preparation involves workstreams that take time.
- Check whether your invoicing software or ERP is already Peppol-compatible, and on what terms.
- Clean up master data: VAT numbers, exact legal names, addresses, purchase-order references, payment terms.
- Identify the problematic flows: credit notes, advance-payment invoices, intra-group recharges, reverse-charge transactions.
- Map incoming invoices and decide who receives, who approves and who books them.
- Budget the project and set its timetable, taking account of the digitalisation support available to companies.
VII. Accounting and VAT points to watch
Moving to electronic invoicing is not merely a change of pipe. It changes the reliable audit trail, the archiving arrangements and the moment at which information becomes usable.
On the VAT side, the obligation is carried by an amendment to the law of 12 February 1979. Mandatory invoice details, the treatment of exempt transactions and the reverse charge will need to be correctly configured in the structured format, failing which rejections will multiply.
On the accounting side, electronic invoicing is a genuine opportunity to automate matching, bank reconciliation and payment-term monitoring. Companies that prepare early gain in cash flow, not only in compliance.
Conclusion
The extension of electronic invoicing to B2B is now politically committed, with a timetable that would start on 1 January 2028 with the obligation to receive. The text still has to be voted on, but the direction is no longer in doubt and the chosen network, Peppol, is already the one used for the public sector.
Companies that open this file in 2027 will experience it as a regulatory constraint. Those that start now can turn it into an automation project that durably reduces their administrative burden.