Luxembourg B2B E-Invoicing: Peppol Proposed for Phased 2028–2029 Rollout

Luxembourg’s Bill No. 8815 proposes mandatory domestic B2B E-Invoicing from 2028, with Peppol as the planned common network. Businesses would first need to receive structured invoices, followed by phased issuance obligations through 2029.

Luxembourg is preparing to extend mandatory E-Invoicing from its existing business-to-government framework to qualifying domestic business-to-business transactions. Bill No. 8815, deposited with the Chamber of Deputies on July 30, 2026, would amend both the Law of May 16, 2019 on electronic invoicing and the Luxembourg VAT Law. The bill remains a legislative proposal, so the dates, scope and technical arrangements described below are not yet final legal obligations.

The proposal builds on Luxembourg’s existing B2G E-Invoicing system, where structured electronic invoices and the Peppol network are already used for public procurement. The government’s official E-Invoicing portal states that the proposed B2B regime would reuse Peppol as the common delivery network. The bill itself refers to a single “common delivery network” and leaves its formal designation and technical parameters to a Grand-Ducal regulation.

The proposed implementation would take place in three stages.

From January 1, 2028, businesses within scope would have to be able to receive and process compliant electronic invoices. The bill enters into force from that date and provides transitional receiving solutions for businesses that are not yet directly connected to the common delivery network.

The obligation to issue and transmit E-Invoices would follow in two phases. From July 1, 2028, it would apply to businesses that exceeded at least two of three thresholds at the end of the 2026 financial year: a balance-sheet total of €7.5 million, net turnover of €15 million, or an average of 50 full-time employees. Businesses below those thresholds would enter the issuance regime by January 1, 2029.

These dates remain proposed. Businesses should therefore use them for planning, but should not treat the timetable as enacted until Bill No. 8815 and the associated regulatory measures complete the legislative process.

The proposed domestic regime is narrower than a general requirement to issue an E-Invoice for every sale. It would cover invoices issued by a supplier established in Luxembourg to a recipient also established in Luxembourg where the place of taxation is Luxembourg and Luxembourg VAT law requires an invoice to be issued.

This distinction is particularly relevant for retailers and e-commerce businesses. Ordinary B2C sales would not automatically become structured E-Invoice transactions. The explanatory material specifically identifies certain distance sales to private consumers as outside the proposed scope, while the general rule is linked to transactions for which VAT legislation requires invoicing.

Relevant cross-border transactions are also not the principal target of this domestic mandate. Luxembourg is using the national E-Invoicing project partly to prepare businesses for the separate VAT in the Digital Age (ViDA) requirements, under which digital transaction reporting for relevant intra-EU transactions is scheduled from July 1, 2030. Bill No. 8815 does not itself establish a general domestic real-time transaction-reporting regime.

A PDF, Word document or image sent by email would not qualify simply because it is electronic. Under Bill No. 8815, the compliant invoice must be issued, transmitted and received in a structured electronic format that allows automated processing. It must comply with the European E-Invoicing standard and one of the permitted syntaxes.

The proposal also makes a practical distinction between the structured invoice and supporting documentation. Only the compliant structured E-Invoice would constitute the authoritative invoice. Supporting documents could be attached, but they would not replace legally required information that must appear in the structured invoice itself.

Businesses using the common delivery network would also need to handle return messages linked to invoices. The proposed law requires Luxembourg-established issuers to be capable of receiving and processing responses sent through the network, so implementation is not limited to creating an XML invoice. ERP and E-Invoicing solutions may also need to manage acknowledgements, technical failures, rejections and other invoice-status messages.

The Luxembourg government has officially stated that the proposed system would reuse Peppol, which already serves as the common network for B2G E-Invoicing. Businesses could connect through a Peppol service provider or through compatible accounting and ERP software rather than necessarily operating their own Peppol Access Point.

The proposal also provides for alternative technical solutions for businesses with limited invoice volumes or without direct network connectivity, including manual solutions comparable to those already available through MyGuichet.lu. Transitional receiving solutions are contemplated until June 30, 2028 for businesses in the earlier phase and until December 31, 2028 for smaller businesses. The exact technical conditions and volume limits should be confirmed against the final Grand-Ducal regulation rather than treated as settled at this stage.

For retailers, the main implementation issue will be distinguishing B2C retail transactions from domestic B2B transactions requiring an invoice. A retailer may continue to process ordinary consumer sales through its existing retail flow while having certain business-customer transactions move through a structured E-Invoicing process.

ERP, accounting, POS and e-commerce providers should therefore consider where the legal invoice is created, whether customer and transaction data are sufficient to identify transactions within scope, and how compliant structured data will be transmitted and received. Return-message handling and reconciliation between the E-Invoice and the underlying sale will also need attention.

From a retail compliance perspective, the most likely implementation risk is treating E-Invoicing simply as a change from PDF to XML. The proposal affects the wider invoice lifecycle: transaction classification, invoice creation, transmission, reception, validation, exception handling and accounting integration all need to work together.

What should businesses prepare now?

Affected businesses should map their domestic B2B invoice flows, determine which 2028 or 2029 issuance phase would apply based on their 2026 figures, and assess whether their current ERP, accounting, POS or e-commerce environment can generate and receive EN 16931-compatible structured invoices.

Businesses should also review Peppol connectivity and the handling of invoice-status messages, while keeping B2C and cross-border processes clearly separated from the proposed domestic mandate. These are preparation recommendations rather than current legal requirements. Companies should continue monitoring Bill No. 8815 and the final Grand-Ducal regulation before implementing technical details that remain subject to change.

The principal official sources are the Bill No. 8815 and its explanatory documentation published by the Luxembourg Chamber of Deputies, Luxembourg’s official E-Invoicing portal and Ministry for Digitalisation guidance on the existing Peppol framework. Source Source 

Mirko Bijeljanin, Junior Legal Consultant at Fiscal Solutions

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