Luxembourg's B2B E-Invoicing Mandate: What Bill 8815 Means for Your Business

What Bill 8815 actually requires

The bill applies to domestic B2B transactions between Luxembourg-established taxable persons subject to VAT invoicing rules. A compliant invoice must be issued, transmitted and received in a structured, machine-readable format. A PDF is no longer an invoice under these rules, though it can travel alongside the structured file as a human-readable attachment.

The rollout is phased across three dates:

• 1 January 2028: the law enters into force and every business in scope must be able to receive a compliant electronic invoice.
• 1 July 2028: large and medium-sized businesses must issue electronic invoices. The threshold is exceeding two of three criteria: a balance sheet total above 7.5 million euros, turnover above 15 million euros, or more than 50 employees.
• 1 January 2029: the issuing obligation extends to everyone else, including small businesses, micro-enterprises and sole traders.

One caveat matters. The bill has not been enacted yet. It still needs parliamentary approval, and both the dates and the scope can shift before it takes effect. Plan against the published timeline, but keep watching the file.

Why the receiving deadline is the one that bites first

Most coverage focuses on the issuing dates, which is a mistake for smaller companies. On 1 January 2028 every business in scope has to be able to receive, and that obligation does not phase in by size. A ten-person consultancy that will not have to issue structured invoices until 2029 still has to accept them from its larger suppliers a full year earlier.

Receiving sounds passive but it is not. Someone has to be registered on the network so senders can find you, the incoming file has to land somewhere your accounting team can work with, and validation failures have to be visible rather than silently dropped. Businesses that treat receiving as an afterthought discover in January 2028 that invoices from their biggest suppliers are arriving somewhere nobody is looking.

The public sector already shows how this works

Luxembourg has been running structured invoicing at scale for years. Since 18 March 2023, suppliers of every size have had to send e-invoices to public bodies, completing a rollout that began with large companies in May 2022. In 2024 alone, close to 1.4 million electronic invoices were received across nearly 800 connected public sector entities. That is up from fewer than a hundred in 2021.

Delivery runs over the Peppol network or MyGuichet.lu, Luxembourg's official portal for digital interactions with the state. More than 1,400 private sector organisations already receive messages through Peppol, which means a meaningful share of the country's businesses have working infrastructure in place before the B2B mandate applies to them.

The B2B framework reuses this foundation rather than replacing it. Bill 8815 builds on a Peppol four-corner model, aligned with the EU's VAT in the Digital Age package, using the European standard EN 16931 with Peppol BIS Billing 3.0 as the primary syntax and UBL 2.1 and UN/CEFACT CII also supported. If you already invoice the Luxembourg state electronically, the technical distance to B2B compliance is short.

How to assess your readiness without overhauling your systems

Start by mapping your current invoicing workflow end to end. Identify the manual touchpoints: data entry, approvals, corrections, chasing missing purchase order references. Those are the steps that break first when the volume of structured invoices rises, and they are also the steps that cost you money today.

Then check three specific things. Can you receive a structured invoice at all, and where would it land? Does your invoice data carry the fields EN 16931 requires, including a valid VAT identifier for every counterparty? And can your accounting software export structured output, or does it only produce PDFs?

Eligible SMEs can get this assessed formally rather than guessing. Fit 4 Digital funds a consultant-led review of your digital maturity across IT infrastructure, cybersecurity and software, ending in a costed action plan.

Funding available to offset the cost

Fit 4 Digital sets the assessment at a fixed price of 5,000 euros and covers it in full with a grant of the same amount, so an eligible business pays nothing for the review itself. Eligibility requires a business permit and an activity that does not appear on the precluded list in the SME general terms. The application has to be filed before you accept a binding quote from a consultant, which is the detail companies most often get wrong.

For the implementation itself, SME Packages Digital covers 70% of eligible costs on projects between 3,000 and 25,000 euros excluding VAT. That can go toward software, integration work or training. Applying while the deadline is still eighteen months away is considerably easier than competing for consultant availability in late 2027.

Steps to take now

• Confirm whether you fall above or below the 1 July 2028 size threshold, since it decides whether you have eighteen months or two and a half years to prepare for issuing.
• Solve receiving first. It applies to everyone on the same date and it is the cheaper half of the problem.
• Choose a Peppol access point provider that covers both B2G and B2B, so the same connection serves public sector clients today and private ones from 2028.
• Clean up counterparty data now. Missing or malformed VAT numbers are the most common reason a structured invoice is rejected.
• Track Bill 8815 through the Chamber of Deputies, and follow guidance from the Chamber of Commerce and Guichet.lu as implementing rules are published.

What to avoid

Do not read "2029" as your deadline because you are a small business. Your receiving obligation starts on 1 January 2028, and your larger customers may well ask you to send structured invoices before the law forces you to.

Do not assume a PDF emailed from your accounting package counts. It does not, under either the current B2G rules or the proposed B2B ones. Structured means machine-readable data, not a document that happens to be digital.

Finally, do not skip the funding. Between the fully covered Fit 4 Digital assessment and a 70% subsidy on implementation, most of the cost of getting compliant is already paid for if you apply in time.