Luxembourg: VAT in the Digital Age (ViDA) and E-Invoicing Requirements

In anticipation of this European transition, Luxembourg submitted draft law No. 8815 to Parliament on 30 July 2026. The draft law is expected to extend the scope of mandatory e-invoicing in Luxembourg beyond business-to-government transactions to certain domestic business-to-business (‘B2B’) transactions from 2028. A related draft Grand-Ducal Regulation specifies the expected delivery network and alternative technical solutions.

These texts remain projects at this stage and may still be subject to amendments or technical adjustments during the legislative process.

Transition to E-Invoicing: Key Insights

E-invoicing is currently mandatory in Luxembourg for transactions with government bodies under public procurement and concession contracts.

Draft law No. 8815 is expected to significantly extend this scope by introducing mandatory e-invoicing for certain domestic B2B transactions.

The draft law would apply only where all four of the following conditions are cumulatively met:

• the issuer is established in Luxembourg;
• the recipient is established in Luxembourg;
• the supply of goods or services is taxable in Luxembourg; and
• Luxembourg VAT law requires an invoice to be issued.

Consequently, the draft law does not introduce a general obligation for all B2B transactions. Transactions involving an issuer or recipient not established in Luxembourg, operations not taxable in Luxembourg, operations covered by Article 262 of Directive 2006/112/EC and transactions for which Luxembourg VAT law does not require an invoice would generally remain outside the domestic regime. The draft law also excludes certain invoices relating to occasional supplies of new means of transport, the Luxembourg housing VAT scheme and specified intra-Community distance sales to private individuals.

The draft law defines a compliant e-invoice as a structured electronic invoice that complies with the European e-invoicing standard and one of the approved syntaxes, enabling automated and electronic processing. A PDF, Word document or scanned image sent by email may qualify as an electronic invoice for VAT purposes, but would not, by itself, qualify as a compliant e-invoice under the proposed mandatory regime.

Legal Framework for E-Invoicing in Luxembourg

Draft law No. 8815 would introduce domestic B2B e-invoicing requirements ahead of the EU e-invoicing and digital reporting rules applicable to covered intra-EU transactions from 1 July 2030.

The draft law provides for the following phased implementation, subject to the final adopted text:

• 1 January 2028: all businesses within scope must be able to receive and process compliant e-invoices;

•  1 July 2028: the obligation to issue and transmit compliant e-invoices is expected to apply to businesses exceeding at least two of the three statutory thresholds at the 2026 financial year-end;
• 1 January 2029: the issuance and transmission obligation applies to all remaining businesses within scope.

For the first issuance phase, the draft law refers to the following thresholds, assessed at the 2026 financial year-end:

• balance sheet total exceeding EUR 7.5 million;
• net turnover exceeding EUR 15 million;
• average number of full-time employees exceeding 50.

A business would enter the first phase only if it exceeds at least two of these three thresholds. For example, a business exceeding the balance sheet and turnover thresholds would be required to issue compliant e-invoices from 1 July 2028. A business that exceeds only one threshold would fall within the second phase starting on 1 January 2029.

The thresholds determine the starting date of the issuance obligation and do not create an exemption from e-invoicing. Businesses exceeding at least two thresholds would enter the first issuance phase on 1 July 2028. The remaining businesses, including those for which at least one of the 2026 criteria cannot be provided, would enter the second phase on 1 January 2029. The obligation to receive and process compliant e-invoices would apply from 1 January 2028 irrespective of these thresholds.

Requirements for E-Invoicing

According to draft law No. 8815, a compliant e-invoice needs to:

• be issued, transmitted and received in a structured electronic format;
• comply with the European e-invoicing standard and an approved syntax; and
• contain all information required under Luxembourg VAT law and other applicable legislation.

According to the draft Grand-Ducal Regulation, Peppol is expected to be designated as the common delivery network for issuing, transmitting and receiving compliant e-invoices.

Recipients would be required to receive and process compliant e-invoices and could not reject them solely because they are issued in that form. Luxembourg-established issuers would also need to be able to receive and process return messages sent through the common delivery network, including confirmations, rejection notices and other messages linked to the original invoice.

Only the compliant e-invoice would constitute the authoritative invoice. Supporting documents may be attached, but an attachment would not itself be treated as the invoice. All legally required invoice information must therefore be included in the structured invoice itself.

The draft Grand-Ducal Regulation provides three alternative solutions through MyGuichet.lu: manual creation and transmission of a compliant e-invoice through an online form; upload and transmission of an already compliant e-invoice through an online form; and receipt of compliant e-invoices and related return messages through a certified professional space. The receipt solution would be available only to issuers or recipients established in Luxembourg and would require a dedicated online application. To use it from the relevant legal deadline, the application would need to be submitted at least one month in advance. These alternatives are intended for transitional use or limited invoice volumes.

The draft Regulation sets the following annual limits for the permanent alternative solutions:

• 75 invoices issued and transmitted; and
• 150 invoices received.

Exceeding these annual limits would not prevent continued use of the alternative solutions, but would trigger progressive usage charges per additional invoice. Under the draft law, the charge would be EUR 2 excluding VAT for each of the first 20 invoices above the relevant limit, EUR 3 for each of the next 30, EUR 4 for each of the next 50 and EUR 5 for each further invoice. The same scale would apply to invoices received.

These limits should be distinguished from the company-size thresholds in the draft law. The company-size thresholds determine when the issuance obligation begins, whereas the annual invoice limits determine how extensively the permanent alternative solutions may be used before the proposed usage charges apply.

Archiving and Accessibility of E-Invoices

Draft law No. 8815 clarifies that the Luxembourg VAT retention obligation applies to the invoices themselves and, where applicable, to copies of those invoices.

Invoices would remain subject to the general ten-year retention period. Businesses would need to preserve the structured e-invoice itself and ensure its authenticity, integrity and legibility throughout that period.

Additional Considerations

The Luxembourg draft legislation and ViDA address related but distinct stages of the e-invoicing transition:

• draft law No. 8815 is expected to introduce mandatory e-invoicing for certain domestic B2B transactions, progressively from 2028;
• ViDA will introduce mandatory e-invoicing and transaction-by-transaction digital reporting for covered intra-EU transactions from 1 July 2030.

Luxembourg businesses should therefore distinguish between the domestic B2B requirements contemplated by the Luxembourg draft legislation and the subsequent EU requirements arising under ViDA.

Direct Reporting and SAF-T System

Luxembourg legislation already provides for the Standard Audit File for Tax, commonly referred to as the FAIA file. It is an electronic XML export of accounting data prepared in accordance with the technical specifications of the Luxembourg VAT authorities and is supplied only upon request, typically during a VAT audit and where the relevant requirements apply. The proposed domestic e-invoicing regime would not replace the FAIA. Unlike the transaction-by-transaction digital reporting framework introduced by ViDA for covered intra-EU transactions from 1 July 2030, the FAIA is an audit file produced on request and is not a real-time reporting system.