E-Invoicing in Luxembourg

When it comes to e-invoicing, Luxembourg is the last BENELUX country to adopt mandatory e-invoicing for B2G transactions, but there are requirements in place.

This small country has a thriving and competitive economy with a strong GDP of 6.9%, according to a 2021 report by the World Bank. Due to their thriving economy, Luxembourg intends to put regulations, policies, and procedures in place so that everything runs smoothly, including a standard for processing all transactions electronically. Additionally, establishing mandatory e-invoicing transactions will improve business transparency, reduce fraud, and provide better insights into spending patterns.

E-Invoicing Plan

In December 2021, the Luxembourg government began the execution of a three-stage plan in which B2G e-invoicing was made mandatory through PEPPOL using the BIS 3.0 format.

Stage one was put into effect in May of 2022. Large companies* were required to implement B2G e-invoicing 5 months after the new law had been executed.

Stage two was put into effect in October of 2022. Medium companies* were required to implement B2G e-invoicing 10 months after the new law had taken effect.

Finally, stage three will be put into effect for small companies* starting March 18th, 2023, 15 months after the law was established.

Luxembourgish companies are also required to archive their electronic invoices for 10 years. Other European countries are required to retain invoices as well, anywhere from 3-10 years. Luxembourg established the 10-year archiving requirement so that they could ensure they met the maximum requirement across Europe. Additionally, archiving outside of Luxembourg is permitted under certain conditions.

While Luxembourg is shifting towards a digital way of doing things, B2B e-invoicing transactions aren’t mandatory yet. However, if a company wishes to send e-invoices to their trading partners, they need to get the buyer’s consent.

*Company size guideline  

A large company needs to meet a minimum of two of the following criteria for two or more consecutive years:  

• The total balance sheet is €20 million (minimum)
• The average number of full-time employees in a fiscal year is 250 (minimum)
• The invoices equal €40 million annually (minimum)

A medium company needs to meet a minimum of two of the following criteria for two or more consecutive years:  

• The total balance sheet ranges from €4.4 million to €20 million
• The average number of full-time employees in a fiscal year is between 50 and 250
• The invoices are between €8.8 million and €40 million annually

A small company needs to meet a minimum of two of the following criteria for two or more consecutive years:  

• The total balance sheet is €4.4 million (maximum)
• The average number of full-time employees in a fiscal year is less than 50
• The invoices are less than €8.8 million annually

For further details in regard to the e-invoicing standards in Luxembourg, you can find more information here.

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Faustine Tournay

Faustine is a Marketing Specialist for SPS Commerce. She is responsible for the marketing strategy for France. She demonstrates her knowledge about the future French Fiscal Law by hosting webinars, writing blogs and whitepapers, and managing events.

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