e-Invoicing in Luxembourg

Following Belgium and the Netherlands, Luxembourg is to become the last of the BENELUX countries to implement mandatory e-invoicing for public authorities. Luxembourgian taxpayers will be required to send invoices in an electronic format, which will replace traditional invoices. Here is all you need to know about the new regulations.

When will B2G e-invoicing be obligatory in Luxembourg?

As stated by the Act of 13 December 2021 amending the Act of 16 May 2019 on electronic invoicing in public procurement and concession contracts, large Luxembourgian companies are obliged to send e-invoices to public authorities as of the 18th of May 2022. This is only five months after the legal framework concerning B2G transactions in Luxembourg entered into force.

The timeline of B2G e-invoicing in Luxembourg

  • Phase I: 18th of May 2022 (large taxpayers)
  • Phase II: 18th of October 2022 (medium-sized taxpayers)
  • Phase III: 15th of March 2023 (small and new businesses)

What is the required format of an e-invoice?

Each electronic invoice must comply with the European standard EN 16931-1 :2017 and the syntax XML UBL or XML UN/CEFACT CII. One of the standards compliant with the European ones is the Peppol Business Interoperability Specification (BIS) 3.0.

How will B2G e-invoicing work in Luxembourg?

Luxembourg is going to use the PEPPOL network for B2G e-invoicing. In order to be part of the PEPPOL network and be able to send invoices to public entities in Luxembourg, a company has to be connected to a PEPPOL Access Point. This is a specialized e-invoicing service provider certified by the PEPPOL network, which complies with the requirements of the PEPPOL network by converting an invoice into the necessary PEPPOL BIS 3.0 format and transferring it through the standard PEPPOL channel (AS4).

Once a company is connected to an Access Point, it is connected to all the PEPPOL participants in the network and can exchange not only invoices with Luxembourgian public authorities, but also other document types with any private company which is also connected to the network through their Access Point. How the PEPPOL mechanism works can be easily understood looking at the “four-corner-model”:

Luxembourg PEPPOL four corner e-invoicing model 

In this model, the invoice issuer sends the document in any format the sender wants (for example,  IDOC, XML, EDIFACT, etc.). It doesn’t matter which format the issuer chooses, because the document is then sent to the sender’s Access Point, responsible for the conversion of the document and transmission to the receiver’s (public entity or private company) Access Point in accordance with the PEPPOL standards. After that, the receiver’s Access Point transfers the invoice in the required format to the receiver. This makes the document exchange between the buyer and the seller convenient and easy, as document conversion and transfer are done by the Access Point in a secure and legally compliant manner.

For smaller and less technologically mature companies, there will be an online form provided to issue and transmit compliant e-invoices by manually entering the core elements of the invoice in the form fields and submitting the completed form. Alternatively, a company may upload an already compliant electronic invoice and submit it via the completed form.

How long is it required to store an electronic invoice?

In Luxembourg, the archiving period is 10 years.

Is a digital signature required for B2G invoices in Luxembourg?

E-signatures will not be obligatory in Luxembourg.

Why should my company switch to e-invoicing?

Apart from the fact of B2G e-invoicing becoming mandatory in Luxembourg in a short time, and taking into consideration the trend of moving to the “clearance” model all around the globe, in which e-invoicing is also required in B2B transactions, e-invoicing brings many advantages in P2P and O2C processes. Not only does it introduce automation to reduce the costs and number of human errors, it also streamlines data exchange and allows better control and monitoring of the whole supply chain process. It is, therefore, highly recommended to switch to e-invoicing as soon as possible, not only to be compliant with the changing requirements regarding B2G and B2B e-invoicing, but also to take advantage of business digitization and modernization.

Key benefits icon

How can Comarch help?

Comarch is a certified PEPPOL Access Point that can mediate in the e-invoicing exchange process, as shown in the image  below. Thanks to it, you can make sure your invoices are fully compliant with the PEPPOL standard.

Luxembourg PEPPOL four corner e-invoicing model

The Comarch e-Invoicing solution is fully compliant with Luxemburg law and supports accounts payable and accounts receivable processes.

Key benefits of Comarch e-Invoicing:

  • Fast and secure data exchange
  • Fewer errors
  • Cost reduction
  • On-time payments
  • Environmental friendliness

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If your company is based or has branches in Serbia, you need to start preparing your billing and tax systems to comply with the new requirements. Click on the button below to get in touch with one of our experts.


Join the companies that have already improved their data efficiency with Comarch e-Invoicing!

Comarch has many years of experience in providing innovative IT products and services allowing for efficient document management and automation of various supply chain processes.

Check out some of our success stories to learn what our clients have achieved by using Comarch EDI, MDM, e-Invoicing (also in a Cloud), and Online Distribution.

Characteristics of the e-invoicing in Luxembourg

E-invoicing for B2B transaction is not mandatory yet. 

Issuing electronic invoices, in terms of B2G transactions, is being introduced partially as follows:

  • As of 18 May 2022 – e-invoicing concerns large economic operators.
  • As of 18 October 2022 – e-invoicing concerns medium sized economic operators.
  • As of 18 March 2023 – e-invoicing concerns small and new businesses.

E-invoice format and platform

E-invoices must comply with European standard EN 16931-1 :2017. There is a possibility to utilize XML UBL or XML UN/CEFACT CII.

Sending B2G e-invoices in Luxembourg is possible thanks to the PEPPOL network.

Peppol option

Each economic operator has several options to make itself fit to issue and transmit e-invoices via Peppol:

  • Rent a Peppol access point
  • Set up its own Peppol access point
  • Use one of the invoicing or accounting software packages (ERP)

Integrity and authenticity

Integrity and authenticity can be ensured by any method, including Advanced Electronic Signature as the one of the examples mentioned in the Notes to the VAT Law.


Storage period – 10 years

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