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FAIA export: what it is and who needs it

FAIA is Luxembourg's SAF-T audit file, one XML per financial year, produced only when the AED asks for it.

By Thinking Desk 3 min read

Key takeaways

  • FAIA is Luxembourg's national SAF-T, one XML file holding a full financial year of bookkeeping for the AED.
  • It is never filed on a schedule, it is produced on request during an AED audit, under article 70(3) of the VAT law as amended in 2008.
  • The AED's published guidance puts outside the obligation anyone not subject to the PCN, under a simplified VAT regime, below 112 000 euros of turnover or under roughly 500 accounting transactions a year.
  • A transaction means a whole posting chain, so a company with one million euros of turnover and 400 transactions is not covered.
  • The current format is FAIA 2.01 with three schemas, one file per calendar year, and a single file even when accounting and invoicing live in different software.
On this page
  1. What is a FAIA file?
  2. Who has to be able to produce a FAIA export?
  3. Which format does the AED expect?
  4. Which accounting software can export FAIA?

What is a FAIA file?

FAIA, the Fichier d'Audit Informatisé AED, is a single XML file that contains a Luxembourg company's whole bookkeeping for one financial year, in a structure the Administration de l'enregistrement, des domaines et de la TVA can read directly. The AED describes it as "largely modelled on the Standard Audit File-Tax of the OECD", so it is Luxembourg's national SAF-T.

It is not a return and it is not filed on a schedule. It is produced on demand, when an AED auditor asks for it during a VAT inspection. The legal hook is the law of 19 December 2008, which amended article 70(3) of the VAT law: where the books, documents and data that must be communicated on request exist in electronic form, they must be handed over on request in a readable and directly intelligible form, certified true to the original, on paper or by any other technical means the administration determines.

Who has to be able to produce a FAIA export?

A VAT taxable person who keeps computerised accounts and is subject to the standardised chart of accounts, the plan comptable normalisé. The AED's own FAQ names four groups that are outside the obligation:

  • taxable persons not subject to the PCN
  • taxable persons under a simplified VAT regime
  • taxable persons whose annual turnover does not exceed 112 000 euros
  • taxable persons whose number of accounting transactions stays within reason, roughly 500 a year, where a manual check is more rational than an electronic export

Two details matter here. First, a transaction is a whole posting chain, not a single line: the AED counts a purchase posted to the expense account, the input VAT account, the supplier account and the bank as one transaction. Its own example is a company with one million euros of turnover but 400 transactions, which it says does not have to produce a FAIA file. Second, the PCN condition does real work, because sole traders, SENC and SCS with annual turnover under 100 000 euros excluding VAT are outside the PCN and therefore outside FAIA.

These thresholds come from published AED guidance, not from a figure written into the VAT law, and the FAQ carrying them is dated March 2013. Treat them as the administration's stated practice and confirm your own case with the AED or your fiduciaire.

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Which format does the AED expect?

FAIA 2.01, still the current published version, with three schemas depending on how your systems are wired:

Schema Use it when
FAIA_2.01_full Accounting and commercial management are one integrated system
FAIA_2.01_reduced_version_A Accounting plus an invoicing module
FAIA_2.01_reduced_version_B Accounting only, invoices written outside the system

The file has four blocks: Header, MasterFiles, GeneralLedgerEntries and SourceDocuments. One file covers exactly one period, aligned on the calendar year, and a truncated year is not accepted, so an audit over three years means three files. Entries that have nothing to do with VAT still go in, because the export has to cover the entire bookkeeping. If you run accounting in one package and invoicing in another, the AED still expects one single file, not two. If your books are in a currency other than the euro, supply the conversion key alongside the file.

Which accounting software can export FAIA?

Odoo documents it as a built-in function of its Luxembourg localisation, under Accounting, Reporting, General Ledger, Export FAIA. Exact WinBooks documents a FAIA module in its help portal but states that only FAIA 2.01 reduced version B is available, which is the accounting-only schema, so ask which schema applies if you also run its commercial management module. Sage documents a FAIA export in its own BOB 50 help portal, and Horus names FAIA on its Luxembourg page. Before signing anything, ask the vendor to generate a FAIA file from a demo database and open it against the published XSD. See our accounting software comparison and the Odoo profile for where each one stands, and which VAT rates apply in Luxembourg for the rate logic the file has to reflect.

Questions and answers

Do I have to send a FAIA file with my VAT return?
No. The AED is explicit that the FAIA file is not filed with the VAT return. It is produced only when an auditor asks for it during an inspection, within the deadline the auditor sets.
Is FAIA the same thing as SAF-T?
FAIA is the Luxembourg implementation of SAF-T. The AED says the file is largely modelled on the OECD Standard Audit File-Tax, but the schemas, field list and version numbering are Luxembourg specific, so a SAF-T file built for another country will not pass.
Which FAIA schema should I use?
Full if accounting and commercial management are one integrated system, reduced version A if you have accounting plus an invoicing module, reduced version B if you keep accounting only and write invoices outside the software.
What if my accounting and invoicing are in two different programs?
The AED still expects one single FAIA file covering both systems. Producing two files, one per program, is not accepted, which is a real argument for keeping ledger and invoicing in the same package.

Sources

Every price and fact above was checked against these pages on the date shown.

  1. [1] AED, FAIA, Portail de la fiscalité indirecte, legal basis and scope accessed 2026-11-11
  2. [2] AED, FAIA FAQ, version mars 2013, thresholds, transaction definition, schemas and delivery accessed 2026-11-11
  3. [3] AED, FAIA 2.01, schemas and field descriptions accessed 2026-11-11
  4. [4] AED, L'informatique au service de la taxation TVA, FAIA modelled on OECD SAF-T accessed 2026-11-11
  5. [5] Guichet.lu, Plan comptable des entreprises, PCN scope and the 100 000 EUR exemption accessed 2026-11-11
  6. [6] Odoo 19.0 documentation, Luxembourg fiscal localization, FAIA export accessed 2026-11-11
  7. [7] WinBooks help portal, FAIA module, only FAIA 2.01 reduced version B available accessed 2026-11-11
Topics faiasaf-tluxembourgauditaccounting