e-Invoicing in Luxembourg

Luxembourg, after Belgium and the Netherlands, is the last BENELUX country to implement mandatory e-invoicing for public authorities. 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 have been obliged to send e-invoices to public authorities since 18 May 2022. Even if the entity is outside Luxembourg, but issues invoices to public entities in Luxembourg, it must send them in electronic form.

E-invoicing process description

E-invoicing process description

Luxembourg uses the PEPPOL network for B2G e-invoicing. To be part of the PEPPOL network and send invoices to public entities in Luxembourg, a company must be connected to a PEPPOL Access Point. The Access Point company should be specialized provider of e-invoicing services certified by the PEPPOL network, which meets PEPPOL requirements by converting invoices to the necessary PEPPOL BIS 3.0 format and sending them via the standard PEPPOL channel (AS4). 

Each business entity has several options to be able to issue and send e-invoices via PEPPOL:

  • Establish cooperation with a service provider that is a PEPPOL access point
  • Set up its own PEPPOL Access Point
  • Use one of the invoicing or accounting software packages (ERP)

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.

For smaller and less technologically mature companies, an online form has been made available for issuing and sending compliant e-invoices. Its completion consists in manually entering the basic elements or uploading an already compliant electronic invoice.

Implementation timeline

  • Since the 18 May 2022, large Luxembourgian companies have been obliged to send e-invoices to public authorities
  • Since 18 October 2022, the obligation has covered medium-sized taxpayers
  • Since 15 March 2023, the obligation has been extended to small and new businesses

What is the required format of an e-invoice

What is the required format of an e-invoice?

Sending B2G e-invoices in Luxembourg is possible thanks to the PEPPOL network. E-invoices must comply with European standard EN 16931-1 :2017. There is a possibility to use 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 integrity and authenticity may be ensured?

How integrity and authenticity may be ensured?

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. A digital signature is not obligatory for B2G invoices in Luxembourg.

Archiving requirements for e-invoicing in Luxembourg

Required storage period is 10 years.

How we can help

Comarch covers B2G transaction via Peppol.

Why is Comarch the best choice?

We have 20+ years of experience in carrying out various EDI, e-invoicing, and other document exchange projects around the world. In those years, we have successfully connected more than 130,000 entities from over 60 countries.

  • 1. Legal compliance

    Full compliance with the latest data exchange regulations and modern data transfer standards

  • 2. Digitization

    Applying new technologies and IT solutions in order to streamline workflows and automate activities and procedures

  • 3. Individual approach

    Tailor-made solutions based on processes specific to each company – own road map and a suitable pace of changes

  • 4.Security

    Highest level of security for all sensitive and important company data

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    Legal regulation changes in Luxembourg

    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 April 2019 – e-invoicing received for central public sector bodies

    • As of 18 April 2020 – e-invoicing received for sub-central public sector bodies

    • 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 newly created

    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.

    Archiving

    Storage period – 10 years.

    Frequently Asked Questions

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