Luxembourg proposes phased mandatory B2B e-invoicing from 2028 under the EU's ViDA framework.
Luxembourg’s parliament is considering a draft law submitted on 30 July 2026 that would introduce mandatory electronic invoicing for domestic Business-to-Business (B2B) transactions from 2028. The draft law (Bill 8815) would amend the Law of 16 May 2019 on electronic invoicing and transpose Article 1 of Council Directive (EU) 2025/516 under the EU’s VAT in the Digital Age (ViDA) Package.
The proposed rules would extend Luxembourg’s existing electronic invoicing framework beyond Business-to-Government (B2G) transactions and introduce a phased B2B rollout beginning in 2028.
E-invoice reception from January 2028
From 1 January 2028, all businesses established in Luxembourg would have to be capable of receiving and processing compliant electronic invoices.
Temporary alternative technical reception solutions would be permitted during the transition to help businesses establish the necessary connections.
The mandatory issuance of structured electronic invoices would then be introduced according to business size.
From 1 July 2028, businesses meeting at least two of three thresholds, based on their position at the close of the 2026 financial year, would have to issue and transmit structured electronic invoices.
The thresholds are:
- total balance sheet of EUR 7,500,000;
- net turnover of EUR 15,000,000; or
- an average of 50 full-time employees.
From 1 January 2029, the obligation would apply to all other businesses required to issue invoices under the proposed framework.
Scope of the proposed rules
The mandatory framework would cover invoices issued by businesses established in Luxembourg to recipients established in Luxembourg for goods and services where the place of taxation is Luxembourg and an invoicing obligation exists under the VAT law.
Certain transactions would be excluded, including transactions covered by Article 262 of Council Directive 2006/112/EC, occasional sales of new transport vehicles by individuals who temporarily acquire taxable status, housing transactions covered by the temporary “VAT lodging” (TVA logement) scheme, and certain intracommunity B2C distance sales of goods deemed to take place in Luxembourg.
Structured format required
The draft law defines a “compliant electronic invoice” (facture électronique conforme) as an invoice issued, transmitted and received in a structured electronic format that enables automated and electronic processing.
The invoice would have to comply with the European standard EN 16931 and use authorised XML syntaxes.
Standard PDFs, Word documents and image files would therefore not qualify as compliant electronic invoices because they do not provide the required structured format.
Common delivery network proposed
The proposed system would use a single secure common delivery network (réseau de livraison commun) for electronic invoice exchanges.
The network would be required to support digital sovereignty, interoperability and data privacy, while complying with eIDAS requirements for electronic registered delivery services.
State ministries and administrations would use a centralised access point and digital mailroom (salle de courrier digitale). Other public contracting entities would also use the network until they establish their own technical access solutions.
Businesses handling only a limited number of invoices could continue to use alternative manual tools, including forms available through MyGuichet.lu.
However, a progressive “usage fee” (droit d’usage) would apply when these tools are used beyond specified invoice-volume limits. The proposed charges are EUR 2 per invoice for the first 20 invoices above the limit, EUR 3 for the next 30, EUR 4 for the next 50 and EUR 5 for each invoice beyond 100 over the limit.
The same progressive fee structure would apply to both sent and received invoices.
Customer acceptance would no longer be required
The draft would also amend Article 63 of the VAT code to incorporate the definition of a compliant electronic invoice.
Under the proposed rules, recipients would no longer need to provide consent before electronic invoices could be used. A recipient would not be permitted to refuse a compliant electronic invoice.
Invoices and, where applicable, their copies would have to be electronically archived for 10 years. The archiving system would need to preserve the authenticity of the origin and integrity of the content throughout the storage period.
The government estimates that implementation of the draft law would have no impact on the state budget.
The phased approach is intended to give Luxembourg businesses time to adapt before the wider EU VAT in the Digital Age requirements, including the EU digital reporting framework, take effect from 2030.
Earlier, Luxembourg’s government published a draft bill to expand mandatory electronic invoicing from business-to-government (B2G) contracts to domestic business-to-business (B2B) transactions, introducing a phased implementation from 2028.
