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E-Invoicing in Luxembourg

Country Situation

General Description

Luxembourg has implemented mandatory electronic invoicing for all business transactions with public sector entities, as part of its national digitalisation strategy and in alignment with the EU Directive on e-Invoicing in public procurement (2014/55/EU).

The mandate requires suppliers to issue e-invoices in a structured format that complies with European standards, ensuring interoperability across the EU.

While the obligation currently applies only to public procurement, Luxembourg encourages broader adoption across the private sector.

FAQs

Who must comply with the mandate?
All economic operators, regardless of size, legal form or country of establishment, must comply if they invoice Luxembourg public authorities.
This includes:

- Large companies
- Medium-sized companies
- Small and newly created companies
- Foreign suppliers participating in public contracts
There is no mandate for B2B or B2C transactions at present.
Does Luxembourg use a clearance or pre-validation model?
No. Luxembourg relies on a post-audit model, meaning there is no real-time clearance or validation from the tax authority. Public entities perform checks upon receipt.
Are cross-border suppliers included?
Yes. Any supplier established outside Luxembourg that invoices a Luxembourg public authority is subject to the mandate and must issue a compliant structured e-invoice.
Can I continue sending PDF invoices to public authorities?
No. PDFs are not compliant. Only structured formats aligned with EN 16931 are accepted.
Do all public sector bodies accept e-invoices?
Yes. All contracting authorities in Luxembourg covered by the public procurement rules must be capable of receiving EN 16931-compliant invoices.
Does the mandate include credit notes and other invoice types?
Yes. Any document considered an invoice under public procurement, including credit notes, must be issued in a compliant structured format.
What happens if a supplier does not comply with the e-invoicing requirement?
A public entity may reject an invoice that does not meet the mandatory structured format requirements. As a consequence, payment processing may be delayed until a compliant invoice is submitted. While the law does not specify direct financial penalties for non-compliance, failure to issue a valid invoice can affect contractual obligations and timelines.

Country Specs

Mandate StatusMandatory
Model TypeInteroperability / Post-Audit
Government EntityMinistry for Digitalisation
FormatsUBL 2.1, CII (Cross Industry Invoice)
Infrastructure / PlatformPeppol
E-signature RequiredNo
Key DeadlinesProgressive B2G e-invoicing mandate, compliant with EN 16931, for all suppliers to Luxembourg public bodies.

18 May 2022: Large companies

18 October 2022: Medium companies

18 March 2023: Small / newly created companies
AR MandatorySince 18 March 2023, all suppliers regardless of size must issue and send electronic invoices to public authorities.
AP MandatoryAll public sector entities (ministries, municipalities, public institutions) must be able to receive, process, and store e-invoices in the EN 16931 format via Peppol.
Peppol AvailableYes
Domestic TransactionsYes, for B2G only.
Cross-border TransactionsAny supplier invoicing a Luxembourg public body must issue and send electronic invoices.
Archiving Period10 years + 1
Archiving AbroadAllowed, as long as tax authorities have immediate online access, data integrity and readability are guaranteed, and prior authorization is obtained if storage is outside the EU.

Contact an expert

Feeling lost or need more info about this e-invoicing mandate? ecosio can help!

Our team of e-invoicing experts is ready to guide you through everything needed to stay compliant—not just with this mandate, but with all current and upcoming e-invoicing requirements worldwide.
Send us your questions. We’ll provide clear, actionable answers!

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