Bill for Mandatory B2B E-Invoicing

The Luxembourg government has introduced Bill 8815, which aims to make electronic invoicing compulsory for domestic business-to-business (B2B) transactions. The proposed legislation would broaden the scope of the electronic invoicing system already applicable in the public procurement sector so that it also covers transactions between businesses established in Luxembourg.

The requirement would concern invoices that must be issued under Luxembourg VAT rules where both the supplier and the customer are established in Luxembourg and the relevant supply of goods or services is subject to VAT in Luxembourg.

To qualify as a compliant electronic invoice, the invoice would have to be created, transmitted and received in a structured electronic format enabling automated processing and meeting the relevant European standard as well as the permitted syntaxes. Documents such as PDFs, Word files, scanned invoices or image files would therefore not meet the legal definition of an electronic invoice. Only an invoice issued in the required structured format would be regarded as legally valid, although supplementary documents could still be attached without themselves being considered invoices.

Customers would not be required to give prior consent to receive electronic invoices and would not be entitled to refuse a compliant invoice merely on the basis that it has been issued electronically. Self-billing would continue to be allowed, provided that the arrangement has been agreed beforehand and that each invoice is accepted by the supplier.

Businesses would be required to rely on a common delivery network that is interoperable and secure. They would also have to be technically capable of receiving and processing electronic invoices, together with any related status notifications or response messages. Suppliers would not be allowed to impose additional charges on customers for issuing invoices in the required electronic format.

The new rules would be introduced progressively. From 1 January 2028, all businesses falling within the scope of the legislation would have to be capable of receiving electronic invoices. From 1 July 2028, the obligation to issue electronic invoices would apply to companies exceeding at least two of the following three criteria: a balance-sheet total of EUR 7.5 million, annual turnover of EUR 15 million, or 50 employees. The issuance obligation would then be extended to all other businesses concerned from 1 January 2029.

Transitional arrangements would be made available to businesses with limited technical resources or very low invoice volumes, with the applicable thresholds to be determined by regulation. Once those thresholds are exceeded, progressive usage charges ranging from EUR 2 to EUR 5, excluding VAT, could apply for each invoice issued or received.

​​​​​​​Bill 8815 is currently being examined by the Luxembourg parliament