Skip to main content
Luxembourg Official

Luxembourg bill 8815 sets e-invoicing deadlines for domestic B2B trade

Luxembourg bill 8815 sets e-invoicing deadlines for domestic B2B trade
©Shutterstock

Finance Minister Gilles Roth filed bill 8815 on 30 July 2026, extending mandatory electronic invoicing to transactions between Luxembourg companies. Reception starts in January 2028, leaving businesses and their fiduciaries 17 months to prepare.

The bill never names Peppol.

Reception first, issuing in two phases

Under article 13 of the bill, the law enters into force on 1 January 2028, when every in-scope recipient must receive and process compliant e-invoices. Issuing follows in two waves. Companies that exceeded two of three criteria at their 2026 closing, a €7.5 million balance sheet, €15 million net turnover or 50 full-time staff, must issue from 1 July 2028 at the latest. All others, and firms unable to supply 2026 figures, follow on 1 January 2029. Published commentaries diverge: a KPMG Luxembourg flash of 3 August dates the large-company obligation to January 2028, while Deloitte’s footnotes cite €25 million, €250 million and 250 staff for the first wave. The parliamentary file records only a rapporteur appointment in the Finance Committee on 18 September, with no Council of State opinion published yet.

Peppol and the ViDA directive

The bill never names Peppol. It refers to a “common delivery network”, to be designated by grand-ducal regulation against criteria such as interoperability, security and openness. The government’s e-invoicing portal states that the bill reuses Peppol, already used in public procurement, and Deloitte considers it the likely choice. Paperjam, citing the Chamber of Commerce, reports that almost 1.4 million invoices passed through Peppol in Luxembourg in 2024. The text transposes Article 1 of Directive (EU) 2025/516, known as VAT in the Digital Age. From 1 July 2030, intra-EU transactions will require transaction-by-transaction digital reporting, and the explanatory memorandum warns that companies will run two distinct accounting regimes between 2028 and that date. The bill adds no domestic e-reporting obligation.

What SMEs and fiduciaries face now

A small company issuing from 2029 may still receive structured invoices from larger suppliers as early as July 2028, Deloitte points out. The bill removes the need for recipient consent and states that only the compliant e-invoice is authoritative, with attachments never counting as invoices. Transitional reception tools remain open until 30 June 2028 for larger recipients and 31 December 2028 for smaller ones. The memorandum notes that manual MyGuichet.lu forms still carry about 15% of e-invoices, while the bill charges €2 to €5 per invoice for alternative solutions beyond a cap still to be set by regulation. Deloitte and Paperjam converge on one checklist: audit invoicing processes and ERP systems, check whether accounting software can connect to the network, and map which clients and suppliers fall in scope and when. Paperjam reports that an existing programme covers 70% of eligible software projects costing €3,000 to €25,000 before VAT.

“The transitional measures should not be viewed as a postponement of the reception obligation,” said Frank Heykes, Partner, VAT & Indirect Tax, Grant Thornton Luxembourg.

Story generated by AI and proofread by Marc Auxenfants