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Luxembourg e-invoicing obligation: what a small vendor must actually do

Every company that invoices the Luxembourg state must send a structured electronic invoice through Peppol or MyGuichet.lu, and has had to since 18 March 2023.

By Thinking Desk 6 min read

Key takeaways

  • Since 18 March 2023 every economic operator invoicing a Luxembourg public body must send a compliant electronic invoice, whatever the amount.
  • The required format is Peppol BIS Billing 3.0 in XML UBL, conforming to EN 16931-1:2017. XRechnung 3.0.1 is also accepted.
  • Only two channels are legal: the Peppol delivery network, or the online forms on MyGuichet.lu. Email with a PDF attached is not a legal channel.
  • The state's Peppol participant identifier is 9938:LU10889245, operated by the CTIE, and the Luxembourg Peppol Authority is the Ministry for Digitalisation.
  • A domestic business to business obligation is proposed in bill 8815 from 1 January 2028, but it is a bill, not yet law.
On this page
  1. Who has to send electronic invoices to the Luxembourg state
  2. When did the Luxembourg e-invoicing obligation start
  3. What format does a compliant Luxembourg e-invoice use
  4. The only two legal channels
  5. What a small vendor must actually do
  6. Four exceptions worth knowing
  7. How this connects to B2B and to the EU ViDA timetable

Who has to send electronic invoices to the Luxembourg state

Every economic operator that invoices a Luxembourg public body, regardless of the amount. The government e-invoicing portal puts it plainly: all companies carrying out work for public sector bodies, which it lists as the State, the municipalities and public establishments, are concerned regardless of the amount of the invoice. There is no threshold below which a paper invoice is still acceptable.

The obligation comes from the law of 13 December 2021, which amended the law of 16 May 2019 on electronic invoicing in public procurement and concession contracts. It was phased in by company size, and that phase-in is now complete.

When did the Luxembourg e-invoicing obligation start

Economic operator Obligation applies from
Large 18 May 2022
Medium 18 October 2022
Small, and newly created 18 March 2023
Everyone, in practice since 18 March 2023

The three dated steps are published by the Chamber of Commerce and the Chambre des Métiers, which describe them as five, ten and fifteen months after the law entered into force. The government pages now state only the end point: Guichet.lu says the obligation applies to all economic operators under a public procurement or concession contract since 18 March 2023. If you are reading this in 2026, the phase-in is history and the only date that matters to you is the last one.

The size categories were defined by reference to balance sheet total, net turnover and headcount. The Chambre des Métiers fiche gives the thresholds as a balance sheet total above 20 million euros, net turnover above 40 million euros and more than 250 staff for a large operator, and a balance sheet total up to 4.4 million euros, net turnover up to 8.8 million euros and up to 50 staff for a small one, assessed on at least two of the three criteria. Those numeric thresholds are not confirmed by any page on a government domain that we were able to fetch, and the reference financial year cited in that fiche is 2019. Since the obligation now covers everyone, the thresholds are of historical interest rather than practical use, but do not rely on them for anything legal.

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What format does a compliant Luxembourg e-invoice use

A structured XML file, not a PDF. The national e-invoicing portal names the standard as Peppol BIS Billing 3.0 in XML UBL format, conforming to the European norm EN 16931-1:2017. Guichet.lu lists the accepted document types as:

  • Peppol BIS Billing 3.0 invoice in XML UBL
  • XRechnung 3.0.1 invoice in XML UBL
  • XRechnung 3.0.1 invoice in UN/CEFACT CII XML
  • the equivalent credit notes in the same three formats

Two older German formats, XRechnung 2.2.0 and 2.3.1, were accepted only until 1 October 2026, so they are no longer an option. If your software still emits XRechnung 2.3.1, that is now a rejected invoice.

The practical reading of this list: target Peppol BIS Billing 3.0 in UBL. It is the format the Luxembourg authority specifies first, it is the one every Peppol access point speaks, and it is the same specification you will meet in Belgium, France, the Netherlands and the Nordics.

Guichet.lu is unusually direct about this. An operator sends a compliant invoice either through the Peppol delivery network, or, if not connected to Peppol, through one of the two online forms on MyGuichet.lu. Any other channel, email included, is not authorised.

The receiving side is the Centre des technologies de l'information de l'État. The CTIE runs the state's Peppol access point and publishes its participant identifier as iso6523-actorid-upis::9938:lu10889245, that is scheme 9938 for VAT identifiers and the number LU10889245. The Luxembourg Peppol Authority, listed by OpenPeppol, is the Ministry for Digitalisation.

What a small vendor must actually do

If you send two invoices a year to a commune, you do not need to buy anything.

  1. Create a business eSpace on MyGuichet.lu. You authenticate with a LuxTrust product, a Luxembourg identity card with an activated electronic certificate, or an eIDAS means of identification from another member state.
  2. Open the e-invoicing form. The authenticated version pre-fills your company data and returns both the XML file and a PDF copy to your eSpace, which is your proof of transmission.
  3. Enter the invoice: issuer and recipient, invoice number and issue date, payment terms and references, then the lines with their VAT rates. The form calculates the total and produces the compliant XML for you.
  4. Keep the returned XML. It is the invoice, not the PDF.

There is a form without authentication for operators who cannot obtain any of those identity means, but it is worse: no pre-fill, you must first get a one-time code from the invoice recipient, and you must attach an order form or another document establishing the contractual link. Guichet.lu itself says the authenticated form is preferable wherever possible.

If you send dozens of invoices a month, the manual form becomes the bottleneck. At that point you either use accounting or inventory software that emits Peppol BIS 3.0 and sends through a certified access point, or you contract an access point provider separately. The question to ask a vendor is narrow and worth asking in writing: does the product emit Peppol BIS Billing 3.0 in UBL, and does it transmit through a Peppol access point, or does it only produce a file you then upload by hand? Many tools sold in this market do the second and describe it as the first. Our inventory software comparison notes which products make a Peppol claim and which do not, and DepotGest, the warehouse tool published by the same company as this site, makes no Peppol claim on its site at all.

Four exceptions worth knowing

Guichet.lu lists public contracts where the electronic invoicing obligation does not apply: contracts concluded in the field of development cooperation, contracts concluded by diplomatic representations or consulates, contracts for Luxembourg's participation in international exhibitions abroad, and contracts for state visits, official visits or working trips abroad. Everything else is in scope.

How this connects to B2B and to the EU ViDA timetable

Business to business e-invoicing in Luxembourg is not yet obligatory. On 30 July 2026 the government tabled bill 8815, which proposes:

Proposed date Proposed obligation
1 January 2028 All Luxembourg enterprises must be able to receive and process electronic invoices
1 July 2028 Large and medium enterprises must issue and transmit electronic invoices
1 January 2029 All enterprises must issue and transmit electronic invoices

The bill proposes reusing the common Peppol delivery network for mandatory transmission, with alternative technical solutions allowed under conditions. These are dates in a bill. Until it is voted and published in the Journal officiel, treat them as planning assumptions, not deadlines.

Above that sits the EU reform. The Luxembourg portal itself points to the ViDA directive, Directive (EU) 2025/516, and to 1 July 2030 as the EU deadline for cross-border transactions, with digital, near real time VAT data reporting. The sequencing is therefore: B2G is already live and has been since 2023, domestic B2B is proposed for 2028 and 2029, and the cross-border EU layer lands in 2030.

The useful conclusion for a small Luxembourg vendor is that the capability you build for the state is the same capability the 2028 bill would need. A tool that already speaks Peppol BIS Billing 3.0 is not compliance theatre, it is the thing you will be required to have twice over. If your accounting or stock software cannot emit it, that is a reason to change tool, and the honest way to choose one is to read what each vendor actually claims. If you sell such software in Luxembourg, you can tell us what it does.

Still unsure whether the system you need is an ERP or a warehouse system? We answer that in the difference between an ERP and a WMS. If your accountant has also asked you for a FAIA export, that is a separate Luxembourg obligation and we explain it in what the FAIA export is and who needs it.

Questions and answers

Can I still email a PDF invoice to a Luxembourg public body?
No. Guichet.lu states that transmission channels other than Peppol or MyGuichet.lu are not authorised, and gives email as the explicit example of a channel that is not permitted. A PDF is also not a structured electronic invoice, because it cannot be processed automatically.
Does the obligation depend on the size of my invoice?
No. The government e-invoicing portal states that all companies supplying goods or services to public sector bodies are concerned regardless of the amount of the invoice. There is no small value exemption.
Do I need to buy software to comply?
Not necessarily. If you send a handful of invoices to the state each year, the MyGuichet.lu form is enough and it produces a compliant XML for you. Software or a Peppol access point becomes worthwhile once the manual form starts costing you more time than a connector would.
Is the business to business obligation already law?
No. Bill 8815 was tabled on 30 July 2026 and proposes an obligation to receive electronic invoices from 1 January 2028, to issue them from 1 July 2028 for large and medium enterprises and from 1 January 2029 for all enterprises. Until it is voted and published, these dates are proposals.
What is a credit note under these rules?
A credit note is treated as an invoice. Guichet.lu states that from a legal point of view a credit note is to be considered as an invoice and is subject to the same obligations, so it travels through the same two channels in the same formats.

Sources

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

  1. [1] E-facturation, portail de l'Etat luxembourgeois, cadre et champ d'application accessed 2026-11-11
  2. [2] E-invoicing in Luxembourg, English portal, law of 13 December 2021 accessed 2026-11-11
  3. [3] E-facturation, dossiers thematiques, Peppol BIS Billing 3.0 in XML UBL and EN 16931-1:2017 accessed 2026-11-11
  4. [4] Guichet.lu, transmission of a compliant electronic invoice under a public contract, accepted formats, channels and exceptions accessed 2026-11-11
  5. [5] Guichet.lu, manual input of an electronic invoice on MyGuichet.lu, prerequisites and forms accessed 2026-11-11
  6. [6] Guichet.lu (FR), transmission facture electronique, formats et canaux autorises accessed 2026-11-11
  7. [7] CTIE, informations facturation electronique, Peppol participant identifier 9938:LU10889245 accessed 2026-11-11
  8. [8] Chambre des Metiers, fiche pratique facture electronique, phase-in dates and size thresholds accessed 2026-11-11
  9. [9] Chambre de Commerce, echeance pour les operateurs de taille moyenne, phase-in dates accessed 2026-11-11
  10. [10] E-facturation, depot du projet de loi 8815 sur la facturation electronique entre entreprises, dates and ViDA reference accessed 2026-11-11
  11. [11] OpenPeppol, list of Peppol Authorities, Luxembourg entry accessed 2026-11-11
  12. [12] DepotGest product site, no Peppol or e-invoicing claim present accessed 2026-11-11
Topics e-invoicingluxembourgpeppolublcompliancevida

Thinking is published by TTA Technologies in Luxembourg, which also builds LUXPOS, Salonify, BoxBee and DepotGest. Read the full disclosure policy