All about mandatory e-invoicing in Luxembourg

In Luxembourg, e-invoicing became part of public procurement following the law of 16 May 2019, which transposed the EU Directive on electronic invoicing. Since then, government authorities have been required to accept e-invoices, and suppliers must now send them digitally through the PEPPOL network or an approved platform. This began in 2022 and was completed by 2023, ensuring faster payments, less paperwork, and a more secure exchange between businesses and the State.

The Luxembourg government has made e-invoicing mandatory for suppliers dealing with public authorities to improve efficiency and transparency in payments. Since 2022, large and medium-sized businesses have been required to send invoices electronically through the PEPPOL network, with smaller suppliers following in 2023. The mandate applies to B2G transactions and marks a key step toward fully digital public administration in Luxembourg.

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According to the European Commission country sheet for Luxembourg, more than 1 million e-invoices were received via the PEPPOL network in Luxembourg in 2023, and by June 2024, over 760 public-sector bodies were connected to PEPPOL.

Meanwhile, a report of March 2025 by the Benelux Union notes that local municipalities grouped under the SIGI cooperation hub have seen a “considerable increase in outgoing and incoming invoicing” after synchronizing their accounting systems with the PEPPOL access-point mechanism.

These developments show that while the mandate for B2G e-invoicing in Luxembourg is now in place, the focus is shifting to broader uptake, system integration and making the infrastructure work for all public and private participants.

What is e-invoicing and is it mandatory in Luxembourg?

E-invoicing means sending and receiving invoices in a structured digital format instead of using paper or PDFs. This allows businesses and public institutions to process invoices automatically, minimize human error, and complete payments more quickly and efficiently.

In Luxembourg, e-invoicing is mandatory for all business-to-government (B2G) transactions. Following the law of 13 December 2021, which built on the original 2019 framework, suppliers that work with public authorities must issue and send invoices electronically using the European standard EN 16931.

What is Peppol?

Peppol (Pan-European Public Procurement Online) is an international interoperability framework that allows secure and standardised exchange of electronic business documents, e-invoices in particular, between other companies and the public authorities of various countries.

It is an e-invoicing network, which helps to standardize different packages of technical standards, agreed-upon parameters, and rules of governance that make systems in different territories work together efficiently and predictably.

Why Luxembourg uses Peppol

• Government support and strategy
  Luxembourg adopted Peppol to digitalize public procurement and invoicing as part of its national digital strategy. The Law of 13 December 2021 made e-invoicing mandatory for public contracts, promoting efficiency, transparency, and automation.
• Mandatory for B2G
  Since 2022, all businesses invoicing public bodies must use Peppol, rolled out in stages for large, medium, and small operators. This ensures a single, reliable system for all government suppliers.
• EU standards and cross-border trade
  Luxembourg follows the EU e-invoicing standard EN 16931, using Peppol to enable secure, compliant, and seamless cross-border invoicing across Europe.
  
  

Luxembourg E-Invoicing Legislative Timeline

B2G (Business-to-Government) E-Invoicing:

• 14 December 2021 –  Publication of the law amending the Law of 16 May 2019 on electronic invoicing in public procurement and concession contracts.
• 18 May 2022 – Large businesses (over 250 employees) required to issue e-invoices to public sector bodies.
• 18 October 2022 – Medium-sized businesses (50–249 employees) required to issue e-invoices to public sector bodies.
• 18 March 2023 – Small businesses and newly established firms are required to issue e-invoices to public sector bodies.
  
  

B2B (Business-to-Business) E-Invoicing:

• E-invoicing for B2B transactions remains voluntary in Luxembourg.
  
  

B2C (Business-to-Consumer) E-Invoicing:

• No current mandatory requirements for B2C transactions in Luxembourg.

B2G (Business-to-Government) Transactions

Luxembourg has adopted e-invoicing for public procurement to make billing faster and more transparent. Under the law of 13 December 2021, all suppliers to public authorities must send invoices electronically using the European standard EN 16931. The rollout began with large companies in May 2022, medium-sized companies in October 2022, and small or new suppliers in March 2023.

Enhanced Requirements:

• Invoices must be submitted in a structured XML format that complies with the European standard EN 16931.
• Suppliers are required to send e-invoices through the PEPPOL network or via the national MyGuichet.lu platform, both recognized by the Ministry for Digitalisation.

Practical Considerations:

Standardized e-invoicing in Luxembourg helps reduce manual work, cut errors, and speed up payments in public procurement. Invoices submitted through PEPPOL or MyGuichet.lu are validated and paid more efficiently, and while the rule applies only to B2G transactions, many businesses are adopting e-invoicing more broadly to align with EU digital standards and streamline their accounting.

B2B (Business-to-Business) Transactions

In Luxembourg, e-invoicing for business-to-business (B2B) transactions is not mandatory, but many companies are gradually adopting it to make billing faster, more reliable, and easier to manage. E-invoicing helps automate payment processes, reduce manual data entry errors, and maintain clear digital records for accounting and audits. 

As more European countries move toward digital invoicing, Luxembourgish businesses are also embracing these standards to stay competitive and aligned with EU digital transformation goals.

There are no legal requirements for B2B e-invoicing in Luxembourg yet, but companies can voluntarily use structured formats like XML or UBL and send invoices through secure platforms such as PEPPOL. This helps automate billing, ensure data accuracy, and align with European interoperability standards.

B2C (Business-to-Consumer) Transactions

In Luxembourg, businesses are not required to issue electronic invoices when selling to consumers, they may continue to use paper or PDF invoices. According to the European Commission’s country factsheet, the e-invoicing mandate applies only to business-to-government (B2G) transactions and does not cover business-to-consumer (B2C) sales.

Fiscalisation

Unlike some other European countries, Luxembourg doesn’t have a certified cash register or “fiscal device” system. Still, businesses handling cash need to follow strict accounting and anti-money-laundering rules. 

According to Guichet.lu, any business that accepts cash payments must issue proper receipts, keep accurate records, and verify customer identity if the payment is €10,000 or more. These steps are meant to make transactions more transparent and prevent tax evasion even without a formal fiscalisation system in place.

Handling Foreign Electronic Invoices and Cross-Border Compliance

Foreign suppliers working with Luxembourg’s public sector must follow the country’s e-invoicing law of 13 December 2021, which requires all invoices for public contracts to be issued electronically. These invoices must use the European standard EN 16931 and be sent either through the Peppol network or the government’s online portal, MyGuichet.lu, for those without Peppol access.

Currently, this rule applies only to business-to-government (B2G) invoices. Foreign companies should still make sure their invoices meet all record-keeping and authenticity requirements, keeping documents for at least ten years. It’s also important to comply with VAT and tax rules in both Luxembourg and their home country to avoid delays or penalties.

Non-Compliance Penalties in Luxembourg

For suppliers working with Luxembourg’s public authorities, it’s important to follow the e-invoicing rules set out by the Law of 13 December 2021. If an invoice isn’t sent electronically in the required EN 16931 format through approved platforms like PEPPOL or MyGuichet.lu, public entities can reject it, leading to delayed payments and administrative follow-ups.

Although the law doesn’t specify fixed monetary fines for non-compliance, repeated failures to meet the e-invoicing obligation can result in contract suspension or payment delays under public procurement rules.

Your trusted partner for E-Invoicing in Latvia

E-invoicing in Luxembourg is moving fast toward digital efficiency, and staying compliant with new requirements can feel challenging. At DDD Invoices, we make the process effortless. Our platform fully supports Luxembourg’s e-invoicing standards and connects smoothly with the PEPPOL network used for public sector transactions.

We help you send, receive, and store invoices securely while meeting both local and EU regulations. You’ll save time, cut down on manual work, and reduce the risk of errors.

Whether you’re a small business going digital for the first time or an enterprise upgrading your invoicing system, DDD Invoices ensures you stay compliant and efficient, so you can focus on running and growing your business.

FAQs

When did e-invoicing become mandatory in Luxembourg?

E-invoicing became mandatory for B2G (Business-to-Government) transactions in stages starting from 2022. Since March 18, 2023, all suppliers (large, medium, and small businesses) that send invoices to Luxembourg’s public sector must issue structured electronic invoices.

Who needs to use e-invoicing in Luxembourg?

Any supplier to public authorities whether local or international  must send their invoices electronically through PEPPOL or MyGuichet.lu. For B2B and B2C transactions, e-invoicing is still voluntary, but many companies are adopting it to simplify accounting and stay aligned with EU digital standards.

Is there a penalty for not following the rules?

If a supplier sends a paper or non-compliant invoice to a public entity, the invoice may be rejected or returned unpaid. Persistent non-compliance can also lead to contract disputes or administrative penalties under public procurement law.