Luxembourg proposes mandatory B2B e-invoicing from 2028 under ViDA rules
Luxembourg's parliament is considering a draft law to require all businesses to receive electronic invoices from January 2028 and issue them from July 2028, phased by company size, under the EU's ViDA framework.
Luxembourg has proposed mandatory B2B e-invoicing under the EU’s ViDA framework, with a phased rollout starting in 2028. All businesses must accept compliant electronic invoices from January 2028; issuance becomes mandatory from July 2028 for larger firms and January 2029 for all others.
Luxembourg’s parliament is considering Bill 8815, a draft law that would make electronic invoicing mandatory for domestic business-to-business transactions. The bill was deposited on 30 July 2026 and transposes EU Directive 2025/516 under the VAT in the Digital Age (ViDA) framework.
The proposal introduces a phased rollout beginning in 2028. From 1 January 2028, all businesses established in Luxembourg must be capable of receiving and processing compliant electronic invoices. Temporary alternative technical solutions would be permitted during the transition.
Phased issuance requirements
Mandatory issuance of structured electronic invoices follows a size-based timeline:
- From 1 July 2028: businesses meeting at least two of three thresholds must issue structured invoices. The thresholds are a total balance sheet of EUR 7,500,000, net turnover of EUR 15,000,000, or an average of 50 full-time employees (measured at the close of the 2026 financial year).
- From 1 January 2029: all other businesses required to issue invoices must do so in structured format.
Technical standards and scope
A compliant electronic invoice must be issued, transmitted and received in a structured electronic format that enables automated processing. Invoices must comply with the European standard EN 16931 and use authorised XML syntaxes. Standard PDFs, Word documents and image files do not qualify.
The mandatory framework covers invoices issued by Luxembourg businesses to recipients in Luxembourg for goods and services where the place of taxation is Luxembourg. Certain transactions are excluded, including those covered by Article 262 of Council Directive 2006/112/EC, occasional sales of new transport vehicles by individuals, housing transactions under the temporary VAT lodging scheme, and certain intracommunity B2C distance sales.
Common delivery network and consent
The system would use a single secure common delivery network for electronic invoice exchanges. State ministries and administrations would use a centralised access point and digital mailroom. Other public contracting entities would use the network until they establish their own technical solutions.
Businesses handling only a limited number of invoices could continue to use alternative manual tools through MyGuichet.lu, but a progressive usage fee would apply beyond specified invoice-volume limits: EUR 2 per invoice for the first 20 invoices above the limit, EUR 3 for the next 30, EUR 4 for the next 50, and EUR 5 for each invoice beyond 100 over the limit. The same fee structure applies to both sent and received invoices.
Under the proposed rules, recipients would no longer need to provide consent before receiving electronic invoices. A recipient would not be permitted to refuse a compliant electronic invoice. Invoices and their copies must be electronically archived for 10 years, with systems preserving the authenticity of origin and integrity of content throughout storage.
Luxembourg’s government estimates the draft law would have no impact on the state budget. The phased approach is intended to give businesses time to adapt before wider EU ViDA requirements, including the EU digital reporting framework, take effect from 2030.