Luxembourg Approves a Bill Extending Mandatory E-Invoicing to Domestic B2B Transactions in Stages from January 2028
KGT Country Update | Luxembourg | July 23, 2026
On July 17, 2026, the Luxembourg government approved a bill that would extend mandatory electronic invoicing beyond public procurement to transactions between businesses established in Luxembourg.
According to the Chamber of Commerce, all companies would have to be able to receive electronic invoices from January 1, 2028, large and medium-sized businesses would have to issue them from July 1, 2028, and the requirement would extend to all other companies from January 1, 2029.
The government also approved a proposed Grand-Ducal regulation establishing a common network — built on Peppol — and alternative ways of sending and receiving invoices.
Background
Luxembourg first required public bodies to accept structured electronic invoices in 2019, but voluntary uptake by suppliers remained negligible — a 2021 explanatory memorandum noted that e-invoicing was almost non-existent in both public- and private-sector transactions.
Parliament subsequently made e-invoicing compulsory for suppliers billing public bodies, phased by company size, using the Peppol network. That infrastructure is now well established: almost 1.4 million invoices passed through Peppol in Luxembourg in 2024, with about 800 public bodies and more than 1,400 private entities connected. The new bill converts this proven B2G model into a generalized domestic B2B obligation.
The Legislative Change
The bill approved by the Council of Government on July 17, 2026 extends mandatory structured e-invoicing to domestic transactions between Luxembourg-established businesses. A structured electronic invoice — not a PDF sent by e-mail — must carry its data in a standard, machine-readable format.
The accompanying draft Grand-Ducal regulation establishes a common exchange network and alternative transmission channels; the government stated the aim is "to avoid invoice issuers and recipients having to deploy and use separate, non-interoperable technical solutions."
The precise scope, company-size categories, exceptions, and enforcement arrangements will be determined by the legal texts, which had not yet been published in parliament’s public dossier system as of July 20, 2026.
Scope
The obligation covers invoices for domestic transactions between businesses established in Luxembourg, exchanged over the Peppol-based common network.
Receiving and issuing duties apply differently during the transition according to company size, so businesses and software providers will need to track which counterparties are covered and when their obligations begin.
Timeline
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July 17, 2026 — Council of Government approves the bill and the draft Grand-Ducal regulation; parliamentary process to follow.
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January 1, 2028 — all companies must be able to receive electronic invoices.
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July 1, 2028 — large and medium-sized businesses must issue electronic invoices.
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January 1, 2029 — the issuance obligation extends to all other companies.
Businesses Affected
All businesses established in Luxembourg are in scope, from large multinationals — including the financial sector and holding-intensive group structures typical of Luxembourg — down to small enterprises in the final phase.
Groups already exchanging structured invoices in Germany, Belgium, or France will recognize the model, but those rules do not cover Luxembourg domestic flows, so a dedicated local readiness workstream is required.
The Chamber of Commerce plans information sessions and workshops, and an existing support program covers 70% of eligible software projects costing between EUR 3,000 and EUR 25,000 before VAT.
Required Actions
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Verify whether your invoicing and accounting systems can connect to Peppol and exchange EN 16931-compliant structured invoices for Luxembourg domestic flows.
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Map counterparty categories (large/medium/other) to determine when issuance obligations start on each side of your invoice flows.
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Plan process redesign in accounts payable and receivable — the 2021 memorandum stressed that the benefits depend on redesigning invoicing, payment, and contract-management processes, not just installing software.
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Monitor publication of the bill and the Grand-Ducal regulation for definitive scope, exemptions, and enforcement provisions.
Practical Implications
Luxembourg's experience shows the effort is organizational as much as technical: one early adopter that connected its SAP system in 2022 reported monthly invoicing work falling from four or five days to a few hours, but described the change as a cross-departmental project.
With Germany, Belgium, France, and now Luxembourg all phasing in domestic mandates on different calendars, multinationals should manage e-invoicing as a portfolio program with shared architecture rather than country-by-country point solutions.
Expected Next Steps
The bill now moves to the Chamber of Deputies; no committee timetable has been announced, and the Chamber of Commerce has called for swift treatment. The final law and Grand-Ducal regulation will fix the definitive scope and technical requirements. KGT will report as the parliamentary texts are published.
How Can KGT Support You?
KGT connects SAP ECC and SAP S/4HANA to the Peppol network through our SAP-integrated e-invoicing add-ons and implements SAP Document and Reporting Compliance (DRC) across the EU. For Luxembourg, we can assess your entity footprint against the 2028–2029 phase-in, design a shared Peppol architecture covering Luxembourg alongside your German, Belgian, and French mandates, and run the implementation from master data readiness through testing and go-live.
Official sources
This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.
