Luxembourg, 2 September 2026. With the publication of draft règlements grand-ducaux on 27 August 2026, Peppol Luxembourg has been formally designated as the network for issuing, sending and receiving structured e-invoices. The draft regulations also set EN 16931 as the semantic standard. The technical shape of the Luxembourg B2B mandate is therefore no longer an open question: businesses and integrators now know which infrastructure and which data model they have to build on.
The designation belongs to Bill 8815, submitted to the Chambre des Députés on 30 July 2026 by Minister of Finance Gilles Roth and currently with the Finance Committee. The Government Council approved the draft law on 17 July. We reported earlier on the content of that bill. What is new now is the formal choice of network.
What Bill 8815 puts in place
The bill amends the law of 16 May 2019 on e-invoicing in public procurement and concessions, and the amended VAT law of 12 February 1979. In doing so, Luxembourg transposes Article 1 of Directive (EU) 2025/516, the ViDA package. The core change: the e-invoicing obligation is extended from B2G to domestic B2B between companies established in Luxembourg.
Three points deserve attention because they cause the most work in practice:
- Only structured e-invoices count. A PDF sent by email does not qualify, however tidy that PDF may be. The structured e-invoice is the legally valid VAT invoice.
- The scope is domestic B2B only. Cross-border B2B and B2C fall outside it. That means you have to be able to separate flows within your own invoice stream.
- There will be no domestic real-time VAT e-reporting. Cross-border ViDA reporting only starts on 1 July 2030. Luxembourg is therefore opting for e-invoicing without a simultaneous reporting layer, unlike several neighbouring countries.
The timeline: 2028 is the year that counts
The obligations arrive in phases:
- 1 January 2028: all companies in scope must be able to receive and process structured e-invoices.
- 1 July 2028: large and medium-sized companies must issue e-invoices.
- 1 January 2029: the issuing obligation applies to all remaining companies, including SMEs.
Much of the coverage leads with 2029. That creates the impression that there are still more than three years before anything has to happen. The impression is wrong. The date that counts for Dutch and Belgian businesses with a Luxembourg entity is 1 January 2028. The receiving obligation comes first and applies to everyone at once, regardless of size. A supplier that has to issue from 1 July 2028 will be sending to buyers who should have been ready since January.
MyGuichet.lu: a fallback, not a destination
The draft regulations of 27 August provide for a transitional and fallback option through a certified MyGuichet.lu business space. For receiving, it may temporarily replace Peppol. The thresholds are based on the figures for financial year 2026: companies exceeding at least two of the three criteria (balance sheet total of 7.5 million euro, turnover of 15 million euro, 50 employees) may use MyGuichet until 30 June 2028. Companies below those thresholds may do so until 31 December 2028. Receiving through MyGuichet is free for the first 150 e-invoices per year, after which per-invoice rates apply on a rising scale.
For issuing, MyGuichet offers two alternatives with no stated end date: manually creating a compliant e-invoice through an online form, or uploading and sending an e-invoice already prepared in the required structured format.
That free threshold of 150 invoices deserves a sober look. It looks like a cost-free solution, but the receiving variant is temporary by definition and ends on 31 December 2028 at the latest. After that you pay per invoice. For anyone invoicing structurally, volume also passes 150 per year quickly, and manual invoice entry through a web form scales poorly beyond a handful of invoices per month. A connection through a Peppol Serviceprovider is then almost always the cheaper and more durable route, and it delivers directly processable data rather than screen work. For an entity with a dozen invoices a year, MyGuichet can be a defensible choice. It is a trade-off based on volume and degree of integration, not a matter of principle.
Peppol Luxembourg fits a broader pattern of network choices
After France and the United Kingdom, Luxembourg is the third jurisdiction within a year to designate Peppol explicitly. That is not a coincidence. Countries are no longer building national networks with their own formats and their own registration, but connecting to existing infrastructure that already works across borders. For software vendors and integrators this means the investment in Peppol capability pays off across an ever-wider footprint: the same connection serves more markets. For how the various countries compare on pace and obligations, see our overview of ViDA implementation by country.
What this means and what to do now
For the business owner or finance manager with a Luxembourg entity:
- Put 1 January 2028 in the plan as the hard date for receiving, not 2029. Work backwards from there: an implementation including testing and master data cleanup realistically takes six to nine months.
- Count your annual volume of purchase invoices within Luxembourg. If it is above 150, MyGuichet is not a serious end state and you are better off skipping the intermediate step.
- Check whether your current accounting or ERP package supports Peppol receiving, and if not, when the vendor will deliver it. Ask in writing and record the commitment.
- Determine which of your entities are established in Luxembourg and therefore in scope. A Luxembourg establishment of a Dutch group counts for domestic flows.
- Look beyond the deadline to enforcement. Our comparison of fines and soft-landing periods in Europe shows how widely countries differ.
For integrators and Peppol Serviceproviders:
- EN 16931 is the same semantic standard already used under Peppol BIS. Anyone already Peppol-capable has done most of the work. Do not budget for a new data model.
- The real work sits in master data: VAT numbers, address details, entity identification and mapping these to Peppol participant identifiers. Start there now, not in 2027.
- Arrange participant registration for Luxembourg entities in good time. A client who wakes up in December 2027 will not be live on 1 January 2028.
- Build routing logic that separates domestic from cross-border. Only the domestic flow is in scope, and that separation has to be demonstrable in your system, not in a spreadsheet.
- Record in your roadmap that no real-time reporting obligation is being added. That saves an entire component compared with markets where clearance does apply.
Caveat: the process is not finished
Both Bill 8815 and the draft règlements grand-ducaux are still in the parliamentary process with the Finance Committee. Dates, scope and technical standards may still change during deliberation. That is no reason to wait: the direction is clear and preparing master data and network connectivity is useful either way. It is a reason to structure your planning so that a shift of a few months does not force a rebuild.
The designation of Peppol Luxembourg simplifies the choice for businesses: one network, one semantic standard and a clear first date. To see which providers can deliver that connection, consult the overview of Peppol suppliers and compare on the basis of your own volume and integration needs.
Sources
- Chambre des Députés, dossier 8815: https://www.chd.lu/fr/dossier/8815
- Luxembourg government e-invoicing portal: https://efacturation.public.lu/fr.html
- Paperjam: https://paperjam.lu/article/obligations-en-matiere-de-facturation-electronique-b2b-prevues-des-2028
- RTC Suite: https://rtcsuite.com/luxembourg-confirms-peppol-for-proposed-2028-b2b-e-invoicing-rollout/
- vatcalc: https://www.vatcalc.com/luxembourg/luxembourg-b2b-e-invoicing-bill-for-2028-rollout/
