🇱🇺 Luxembourg E-Invoicing

Luxembourg E-Invoicing Compliance

E-invoicing is mandatory for every supplier to the Luxembourg public sector: since 18 March 2023, Luxembourg and foreign companies alike must send a structured e-invoice that complies with EN 16931 for every invoice, whatever the amount. Peppol BIS Billing 3.0 in UBL is the recommended format. Between businesses, e-invoicing is still voluntary; bill no. 8815, not yet law, proposes obligations from 1 January 2028. GoRoute, a certified Peppol access point, sends and receives these invoices for you over Peppol.

Luxembourg E-Invoicing Status

B2G (public sector) Mandatory since 18 March 2023
B2B (business) Voluntary; bill 8815 proposes 2028
Format Peppol BIS 3.0 / EN 16931
Channel Peppol or MyGuichet.lu
Regulatory Timeline

How Luxembourg phased in B2G e-invoicing

The law of 16 May 2019 on electronic invoicing in public procurement, amended by the law of 13 December 2021, made e-invoicing to the public sector mandatory. The obligation reached suppliers in three steps during 2022 and 2023.

18 May 2022

Large companies

Large operators, five months after the 2021 law took effect, began sending e-invoices to Luxembourg contracting authorities.

18 October 2022

Medium-sized companies

Operators that did not exceed two of €20 million balance sheet, €40 million turnover and 250 staff at the 2019 close followed five months later.

18 March 2023

Small and newly created companies

Operators that did not exceed two of €4.4 million, €8.8 million and 50 staff, or could not provide 2019 figures. The last step. Since this date the obligation has applied to all suppliers, Luxembourg and foreign, for every invoice regardless of amount.

What GoRoute does for Luxembourg invoices

Certified access point

GoRoute is operated by ClayDesk LLC, a certified Peppol Access Point and SMP provider (POP000991). It serves Luxembourg businesses directly; we found no official requirement for a local entity or registration.

Peppol BIS Billing 3.0

Sends and receives invoices and credit notes in Peppol BIS Billing 3.0, the format every Peppol access point must be able to receive and process.

EN 16931 validation

Checks every document against EN 16931 before it leaves, so an error surfaces in your system rather than at the public body.

Buyer lookup

Looks up whether a buyer is on Peppol before you send, using its scheme 9938 identifier.

REST API

Post invoice data from your own software to the GoRoute API; GoRoute builds, validates and delivers the Peppol document.

Connectors

Send from Microsoft Dynamics 365 Business Central, Odoo, WooCommerce or Shopify without writing XML by hand.

In depth

Luxembourg e-invoicing: what the mandate requires

Scope, format, channels and identifiers, for finance and IT teams that invoice Luxembourg public bodies.

What does the Luxembourg e-invoicing law require?

The law of 16 May 2019 on electronic invoicing in public procurement, amended by the law of 13 December 2021, requires suppliers to send electronic invoices to Luxembourg contracting authorities. The amendment is what made e-invoicing mandatory.

An invoice must comply with the European standard EN 16931, in either UBL or UN/CEFACT CII XML. The recommended format is Peppol BIS Billing 3.0 in UBL, because every Peppol access point must be able to receive and process it (eFacturation: public sector). Public bodies also accept XRechnung 3.0.1 in UBL or CII; XRechnung versions older than 3.0 have been refused since 1 October 2026.

Who does the obligation apply to?

Every supplier that invoices the Luxembourg public sector: the State, municipalities, public establishments and other contracting authorities. Since 18 March 2023 it has applied to all suppliers, for every invoice regardless of amount (Government of Luxembourg, March 2023).

Foreign suppliers are covered in the same way as Luxembourg companies. If your company is based in another country and bills a Luxembourg ministry, municipality or public establishment, that invoice must be electronic too.

How do you send e-invoices to Luxembourg public bodies?

There are two channels. The first is the Peppol network: the Government IT Centre (CTIE) operates the State's Peppol access point, so your access point delivers to it like any other Peppol recipient. The second is MyGuichet.lu, where web forms let you type an invoice in or upload an XML file.

MyGuichet.lu means entering or uploading each invoice by hand. Peppol lets your accounting system send directly. With GoRoute the sequence is:

  1. Connect your system. Use the REST API or a connector for Business Central, Odoo, WooCommerce or Shopify.
  2. Check the buyer. GoRoute looks up whether the public body or business is on Peppol under its scheme 9938 identifier.
  3. Validate. GoRoute checks the invoice against EN 16931 before sending.
  4. Send. GoRoute delivers a Peppol BIS Billing 3.0 invoice or credit note to the recipient's access point.
  5. Receive too. Invoices that suppliers send you over Peppol arrive through the same connection.

Which Peppol identifier do Luxembourg organisations use?

Luxembourg organisations are identified on Peppol under scheme 9938, followed by one of two numbers:

  • the VAT number, for example 9938:lu10061242; or
  • the 11-digit national identification number (matricule) of the legal person, for example 9938:12345678910.

Luxembourg’s official guidance uses 9938 for both forms, and public bodies publish matricule-style IDs under it, such as 9938:00005000041. Peppol’s code list also has scheme 0240 (LU:MAT) for the matricule, but none of the public bodies on the official list uses it.

Is B2B e-invoicing mandatory in Luxembourg?

Not yet. E-invoicing between businesses is voluntary in Luxembourg today. Bill no. 8815, filed in parliament on 30 July 2026, would change that for invoices between businesses established in Luxembourg. It is a bill, not yet law, and its dates may change:

  • 1 January 2028: businesses must be able to receive and process e-invoices.
  • 1 July 2028: issuing, for businesses that exceed two of €7.5 million balance sheet, €15 million turnover and 50 full-time staff at the 2026 close.
  • 1 January 2029: issuing, for all other businesses.

Issuers would also have to be able to receive return messages over the common network, and the recipient’s acceptance would no longer be needed for these invoices.

The EU direction is set. The VAT in the Digital Age (ViDA) package brings e-invoicing and digital reporting for intra-EU B2B transactions from 1 July 2030. A Luxembourg business that already sends Peppol invoices to public bodies can use the same connection for its business customers.

Trading across the region?

Luxembourg's neighbours set their own rules for e-invoicing between businesses. See Belgium, France and Germany for what each requires. GoRoute uses the same API and connectors for each of them. New to Peppol? Start with how the Peppol network works or the glossary.

Invoicing the Luxembourg public sector?

Send Peppol BIS Billing 3.0 invoices from your ERP or online store, validated against EN 16931 before they leave. Book a demo and we will walk through your setup.

Official source: eFacturation Luxembourg — the Luxembourg government's e-invoicing portal. Always confirm current obligations against the authority directly.

Luxembourg E-Invoicing FAQ

Is e-invoicing mandatory in Luxembourg?

Yes, for invoices to the public sector. Since 18 March 2023 every supplier to the Luxembourg State, municipalities, public establishments and other contracting authorities must send electronic invoices, for every invoice regardless of amount. E-invoicing between businesses is voluntary today; bill no. 8815, not yet law, proposes B2B obligations from 1 January 2028.

Do foreign suppliers have to send e-invoices to Luxembourg public bodies?

Yes. The obligation applies to Luxembourg and foreign companies alike. A supplier established outside Luxembourg that invoices a Luxembourg contracting authority must send a structured e-invoice, just as a Luxembourg company must.

What format must a Luxembourg e-invoice use?

It must comply with the European standard EN 16931, in UBL or UN/CEFACT CII XML. Peppol BIS Billing 3.0 in UBL is the recommended format, because every Peppol access point must be able to receive and process it.

How do I send an e-invoice to a Luxembourg public body?

Over the Peppol network, or through the MyGuichet.lu web forms, where you either type the invoice in or upload an XML file. The Government IT Centre (CTIE) operates the State's Peppol access point, so an invoice sent over Peppol reaches it like any other Peppol recipient.

Which Peppol identifier do Luxembourg organisations use?

Scheme 9938, followed by either the VAT number (for example 9938:lu10061242) or the 11-digit national identification number (matricule) of the legal person (for example 9938:12345678910). Luxembourg's official guidance uses 9938 for both; public bodies publish matricule-style IDs under it.

Is B2B e-invoicing mandatory in Luxembourg?

Not yet. E-invoicing between businesses is voluntary in Luxembourg today. Bill no. 8815, filed in parliament on 30 July 2026 and not yet law, would require businesses established in Luxembourg to be able to receive e-invoices from other Luxembourg businesses from 1 January 2028, and to issue them from 1 July 2028 (larger businesses) or 1 January 2029 (all others). At EU level, the VAT in the Digital Age (ViDA) package brings e-invoicing and digital reporting for intra-EU B2B transactions from 1 July 2030.

Can GoRoute send e-invoices for a Luxembourg business?

Yes. GoRoute is operated by ClayDesk LLC, a certified Peppol Access Point and SMP provider (POP000991), and serves Luxembourg businesses directly. Luxembourg's official guidance points businesses to OpenPeppol's list of certified providers, and we found no requirement for a local entity or registration. It sends and receives Peppol BIS Billing 3.0 invoices and credit notes, validated against EN 16931 before sending.

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