Have you ever tried to send an invoice digitally without someone having to manually retype the PDF in the end? What still sounds like a distant dream in many companies is already well established in the Grand Duchy of Luxembourg. While some European neighbors rely on abrupt, legally mandated requirements, Luxembourg impressively demonstrates how a structured, evolutionary transition can succeed. The country has already successfully established electronic invoicing in the public sector (B2G). Now it is preparing for the next step: a comprehensive expansion to all business-to-business (B2B) transactions. Read this article to learn how e-invoicing is being introduced in Luxembourg.
B2G as a Foundation: Luxembourg’s Pioneering Role
Luxembourg set the course for digital invoicing early on. The Act of May 16, 2019 – based on EU Directive 2014/55/EU – laid the foundation for e-invoicing in the public sector (Business-to-Government, B2G). In a phased rollout, central government agencies were first required to be able to receive and process standard-compliant e-invoices starting in April 2019, followed by sub-central entities such as municipalities starting in April 2020.
The actual requirement for companies to submit invoices to public contracting authorities exclusively in electronic form was introduced by an amending law in December 2021. Between May 2022 and March 2023, it became mandatory in stages based on company size. Since March 18, 2023, this B2G requirement has applied without exception to all domestic and foreign suppliers – starting with the first euro, with no de minimis thresholds.
The technical infrastructure behind this success is based on the international Peppol network. Luxembourg deliberately opted against an isolated government invoicing portal and established Peppol as the legally mandated transmission channel. The result has been a success: The number of electronic invoices received via Peppol in Luxembourg rose from fewer than 100 in 2021 to nearly 1.4 million in 2024. The B2G rollout also demonstrates the advantages of an open, interoperable standard. Based on the European standard EN 16931-1:2017, invoice data can be automatically exchanged between different ERP systems and across national borders.
You can learn more about Peppol and SAP DRC here in this article by Aleksandar Lukic and Felix Löffler.
The Transition to B2B: Draft Bill 8815
What has evolved into standard practice through interactions with government agencies is now becoming the norm in general business life. On July 30, 2026, Luxembourg’s Minister of Finance, Gilles Roth, presented Bill No. 8815 to gradually extend the proven B2G model to the domestic B2B sector.
The following table summarizes the planned, phased transition to mandatory B2B e-invoicing in Luxembourg:
| Effective Date | Affected Parties | Legal Requirement |
| January 1, 2028 | All Luxembourg companies | Requirement to receive and process electronic invoices in a structured XML format (primarily via Peppol or, on a transitional basis, alternative receipt solutions). |
| July 1, 2028 | Large and medium-sized companies (revenue > €15 million and total assets > €7.5 million) | Requirement to actively issue and electronically transmit invoices via the Peppol network. |
| January 1, 2029 | All other companies (including small businesses and SMEs) | Mandatory issuance and transmission of structured electronic invoices via the Peppol network (Peppol BIS Billing 3.0), without exception. |
| July 1, 2030 | All EU companies engaged in cross-border B2B trade | Introduction of mandatory real-time reporting (DRR) under the EU ViDA Directive. |
It is important to have a basic understanding of what legally qualifies as an e-invoice. A PDF file sent via email or a scanned paper invoice does not meet the legal requirements. Only structured, machine-readable XML files (preferably in the Peppol BIS Billing 3.0 format based on UBL 2.1) are permitted, as these can be processed directly by the recipient’s system without manual intervention. Although the government provides manual online forms via the Guichet.lu portal, these are intended solely as an emergency and temporary solution for very small volumes. Furthermore, they support only sending, but not the mandatory receipt.
Luxembourg in the European Context: ViDA as a Digital Driver
The expansion to B2B is not a phenomenon unique to Luxembourg but is closely intertwined with the European tax initiative ViDA (“VAT in the Digital Age”). With the adoption of Directive (EU) 2025/516 in March 2025, the Council of the European Union established the legal framework to adapt VAT systems to the digital age. A key objective of ViDA is to reduce the EU VAT gap – estimated at around 128 billion euros in 2023 – through greater transparency and digital reporting. According to the European Commission, cross-border carousel fraud (missing trader fraud) alone results in annual tax losses of between 12.5 and 32.8 billion euros.
As part of the phased ViDA roadmap, structured electronic invoicing will become mandatory for cross-border (intra-Community) B2B transactions in the EU starting July 1, 2030. At the same time, the Digital Reporting Requirements (DRR) will replace the current summary reports with a digital, near-real-time reporting system. A transition period until 2035 applies to existing national reporting systems.
For Luxembourg companies, this means that the phased introduction of the national B2B e-invoicing requirement starting in 2028 and its full implementation by 2029 will simultaneously lay the technological foundation for the upcoming EU-wide ViDA requirements starting in 2030. Since Draft Law 8815 is based on the European standard EN 16931-1:2017, a system that is properly set up from the outset ensures domestic compliance on the one hand. On the other hand, it directly paves the way for harmonized, Europe-wide data exchange.
You can learn more about the ViDA three-pillar model here in this article by Dennis Zielinski and Julia Barbara Krings.
Conclusion: Review Your SAP System Landscape Now
The regulatory deadlines for Luxembourg have been set, and the countdown is on. For companies using SAP, this transformation means that e-invoicing should not be put off until 2028. Adapting posting processes, ensuring master data quality, and integrating the system into the existing IT architecture all require sufficient lead time.
SAP Document and Reporting Compliance (SAP DRC) offers a standardized and future-proof solution. Fully integrated with the familiar eDocument functions, it enables the automated extraction, conversion, and validation of invoice data directly in the SAP backend (whether on S/4HANA or ERP ECC 6.0). In combination with the SAP Business Technology Platform (SAP BTP) and SAP DRC, Cloud Edition – which acts as a registered Peppol Access Point – e-invoices can be sent and received automatically and in compliance with regulations. This is fully aligned with SAP’s strategic “Keep the Core Clean” philosophy.
Take a timely look at your invoicing processes and interfaces to turn this legal requirement into a genuine opportunity for efficiency and automation.
Here at adesso business consulting, we’re here to support you along the way. Drawing on our many years of practical experience, deep SAP expertise, and regulatory foresight, we’ll analyze your existing system architecture. We’ll also guide you through the implementation process and ensure your accounting processes are ready for Luxembourg and the future of ViDA in Europe. Reach out to us – let’s tackle this challenge together!
