Luxembourg Confirms Peppol for Proposed 2028 B2B E-Invoicing Rollout
Luxembourg has taken a further step toward extending mandatory electronic invoicing to domestic business-to-business transactions.
Bill No. 8815 was deposited with the Luxembourg Chamber of Deputies on 30 July 2026. The bill proposes extending the country’s existing B2G e-invoicing framework to qualifying domestic transactions between businesses established in Luxembourg. An accompanying draft Grand-Ducal regulation, made available through Legilux in August 2026, confirms Peppol as the common network for issuing, transmitting and receiving electronic invoices.
The measures remain in draft form and must complete the relevant legislative and regulatory procedures before becoming final. Businesses should therefore treat the dates and technical rules below as proposed requirements that may still change.
A Phased Rollout from 2028
Under the current proposal, the mandate would be introduced in three stages:
- 1 January 2028: All businesses within scope would have to receive and process compliant electronic invoices.
- 1 July 2028: Large and medium-sized businesses would have to issue and transmit compliant electronic invoices.
- 1 January 2029: The issuance and transmission obligation would extend to all remaining businesses within scope.
The July 2028 phase would apply where a business exceeds at least two of the following thresholds based on its 2026 financial year: a EUR 7.5 million balance-sheet total, EUR 15 million net turnover or an average of 50 full-time employees.
Scope and Invoice Requirements
The proposed regime would apply to domestic transactions where the supplier and customer are both established in Luxembourg, the place of taxation is Luxembourg and Luxembourg VAT law requires an invoice to be issued.
Cross-border B2B transactions and B2C transactions are therefore not generally covered by this domestic mandate. Transactions for which there is no VAT invoicing obligation, together with specific statutory exclusions, may also remain outside its scope.
A compliant electronic invoice must be issued, transmitted and received in a structured electronic format that enables automatic processing. A PDF, Word document or image sent by email would not qualify, even if it is readable by a person. The structured invoice would need to comply with the European e-invoicing standard and one of the permitted syntaxes.
The proposal also provides that the compliant structured invoice would be the legally authoritative invoice. Supporting documents may be attached, but all legally required invoice data must appear in the structured invoice itself.
At this stage, the proposal does not introduce a general domestic real-time e-reporting obligation. It is separate from the EU-wide digital reporting requirements under VAT in the Digital Age, which are scheduled to apply to relevant intra-EU transactions from 1 July 2030.
Peppol Confirmed as the Common Network
The draft Grand-Ducal regulation designates Peppol, managed by OpenPeppol, as Luxembourg’s common delivery network for the issuance, transmission and receipt of electronic invoices.
This builds on Luxembourg’s existing B2G infrastructure and provides an interoperable route for exchanging structured invoices through Peppol Access Points. Businesses would also need to process return messages connected with their invoices, meaning that preparation should cover invoice status and exception handling as well as invoice creation.
The draft regulation also provides limited alternatives through MyGuichet.lu:
- an online form for manually creating and transmitting a compliant electronic invoice;
- an online form for uploading and transmitting an invoice already created in a compliant structured format; and
- a certified business space for receiving electronic invoices and related return messages.
The proposed annual thresholds for these alternatives are 75 issued invoices and 150 received invoices, with progressive usage fees applying above the relevant threshold. The receiving alternative would be transitional: it would remain available until 30 June 2028 for businesses in the earlier issuance phase and until 31 December 2028 for other businesses.
Peppol therefore remains the principal route for automated, system-to-system invoice exchange, while the MyGuichet.lu options are intended mainly for transitional or limited-volume use.
Conclusion
The draft regulation provides clearer technical direction by confirming Peppol as the common network and defining the available MyGuichet.lu alternatives. Although the framework is not yet final, it now offers businesses a more concrete path toward the proposed 2028–2029 rollout.
Businesses should continue to monitor Bill No. 8815 and review their transaction scope, ERP readiness and Peppol connectivity ahead of the proposed receipt obligation on 1 January 2028.
