Luxembourg: Government Submits Draft Law for Mandatory B2B E-Invoicing

Background

Luxembourg has required e-invoicing for business-to-government (B2G) transactions since 2022. Now the country is extending that model to domestic business-to-business (B2B) transactions.

On July 17, 2026, the Council of Government approved a draft law that sends mandatory B2B e-invoicing to the Chamber of Deputies. The law amends the Law of May 16, 2019 on electronic invoicing and the VAT Law of February 12, 1979. It also transposes Article 1 of Council Directive (EU) 2025/516 (the ViDA Directive) into Luxembourg law.

Who is in scope

The new B2B obligation applies to invoices:

• Issued by a sender established in Luxembourg to a recipient established in Luxembourg;

• For supplies of goods or services taxable in Luxembourg; and

• Subject to an invoicing obligation under the Luxembourg VAT Law.

Two new concepts of electronic invoice

The law separates two concepts. An ‘electronic invoice’ contains the information the law requires and is issued and received electronically, in any form. A ‘compliant electronic invoice’ goes further. It must follow the European standard EN 16931 and use one of the authorized XML syntaxes, UBL or CII, listed in the Official Journal of the EU under Directive 2014/55/EU.

Only the compliant e-invoice carries legal evidentiary value. Luxembourg VAT law currently requires customer acceptance of e-invoicing for it to count. That requirement also disappears for compliant e-invoices issued under the new obligation.

Obligations for Issuers and Recipients

Issuers must:

• Issue and transmit all invoices within scope exclusively as compliant e-invoices;

• Not charge recipients any additional fee for issuing an e-invoice in place of a paper or non-structured electronic invoice; and

• Receive and process return messages from recipients, such as confirmations of receipt, rejection notices, validation messages, and payment confirmations, through the common delivery network.

Recipients must:

• Accept and process any compliant e-invoice within scope;

• Not reject an invoice on the grounds that it is in electronic structured format; and

• Treat a compliant e-invoice equivalently to a paper or non-structured electronic invoice for all internal processes (verification, validation, dispute, payment, etc.).

One delivery network for the whole country

Luxembourg will route every compliant e-invoice through a single common delivery network. The law sets nine criteria for that network: national and cross-border interoperability, openness (no vendor lock-in), open digital sovereignty (decentralized architecture preferred; no single point of failure), security (encryption, confidentiality, integrity, non-repudiation), privacy and GDPR compliance by default, conformity with the eIDAS qualified electronic registered delivery service definition, wide adoption nationally and cross-border, default support for compliant e-invoice exchange, and default support for all other procurement and billing document types (purchase orders, reminders, etc.).

A Grand-Ducal regulation will designate the specific network that best meets these criteria. The law also introduces a digital mailroom alongside each access point to manage the routing and transformation of incoming and outgoing message flows. Luxembourg doesn’t name Peppol outright, but the criteria track closely with the Peppol network already running for B2G transactions in the country.

Implementation Timeline

Between January 1, 2028 and January 1, 2029, recipients who haven’t connected directly to the common delivery network can use a transitional solution to receive compliant e-invoices, subject to the size-based deadlines above.

Storage

The draft law also updates the VAT invoice storage rulesm to clarify that companies must store the invoices themselves, not just copies, regardless of format they were issued.

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