eInvoicing Documentation
eInvoicing in Luxembourg
Legislation
In Luxembourg, Directive 2014/55/EU has been transposed via the law of 16 May 2019 on electronic invoicing in public procurement and concession contracts. Receiving and processing of compliant eInvoices are mandatory for central public sector bodies as of 18 April 2019. Sub-central public sector bodies are mandated to receive and process compliant eInvoices as of 18 April 2020.
On 14 December 2021, the law of 13 December 2021 amending the law of 16 May 2019 on electronic invoicing in the context of public procurement and concession contracts was published together with the Grand-Ducal Regulation of 13 December 2021 fixing the common delivery network and alternative technical solutions used for electronic invoicing in public procurement and concession contracts.
The law of 13 December 2021 amending the law of 16 May 2019 on electronic invoicing in the context of public procurement and concession contracts makes it mandatory for economic operators to send compliant electronic invoices to public sector bodies in the context of public procurement and concession contracts. Businesses were given different deadlines to comply with the law:
- deadline for large companies: 18 May 2022;
- deadline for medium-size companies: 18 October 2022;
- deadline for small companies and newly created businesses: 18 March 2023 (source).
The Grand-Ducal Regulation of 13 December 2021 determining the common delivery network and the alternative technical solutions used for electronic invoicing in public procurement and concession contracts selects as the common eDelivery network to be used by public sector bodies for the automated receipt of electronic invoices the European Peppol Network[1].
The consolidated version of the amended Law of 16 May 2019 on electronic invoicing in the context of public procurement and concession contracts can be found here:
More information can be found here and here:
eInvoicing platform and eInvoicing management solutions
In Luxembourg, all public sector bodies have to be able to receive electronic invoices via the Peppol network, i.e. they have to be connected to a Peppol access point. Ministries and administrations of the State have to use for this purpose the Peppol access point under the control of the Luxembourg Government IT Centre (Centre des technologies de information de l'État: CTIE). Other Luxemburgish public sector bodies may use the CTIE Peppol access point, but can also use another Peppol access point. As Peppol is a completely decentralised network without any central infrastructure and with hundreds of access points able to communicate directly with each other, no common access point used by all public sector bodies and no central eInvoicing platform exists.
Nevertheless the biggest part of the public sector bodies is using CTIE's access point. The second most used access point solution is the one provided by SIGI (Syndicat intercommunal de gestion informatique), a public sector body managing a large part of the IT of all municipalities, except the city of Luxembourg.
Economic operators can transmit their electronic invoices either directly in an automatised manner via the Peppol network or, if they don't want to use Peppol or are not yet ready for Peppol, via one of two types of web forms provided on the national central portal for citizens and enterprises guichet.lu:
The electronic invoices received via these web forms are afterwards converted, if necessary, in Peppol BIS Billing 3.0 (UBL) XML invoices and dispatched via the Peppol network to the respective public sector body.
Approach for receiving and processing eInvoices
An economic operator can make itself fit to issue and transmit compliant electronic invoices via Peppol by:
- renting a Peppol access point from a specialist service providers;
- setting up its own Peppol access point;
- using one of the invoicing or accounting software packages (ERP) connected to Peppol by default.
Economic operators, which cannot issue and transmit electronic invoices automatically via Peppol, alternatively can use non-automated technical solutions. Two options are available to economic operators:
- the online form for issuing and transmitting a compliant electronic invoice by manually entering the core elements of the invoice in the form fields and submitting the completed form is available on Guichet.lu;
- the online form for issuing and transmitting a compliant electronic invoice by uploading an already compliant e-invoice and submitting this completed form is available on Guichet.lu.
Within the B2G context, all public sector bodies are mandated to receive and process electronic invoices. Within the B2B environment, eInvoices are allowed, however the buyer’s consent is needed for receiving[2].
eInvoicing implementation in sub-central level contracting authorities
All municipalities and other local level public sector bodies are connected to the Peppol network and receive eInvoices via this network. Nearly all of them use the access point solution provided by SIGI (Syndicat intercommunal de gestion informatique), a public sector body managing a large part of the IT of all municipalities, except the city of Luxembourg.
Status on the implementation of the European Standard on eInvoicing (EN)
The European standard on eInvoicing is fully implemented by the usage of Peppol BIL Billing 3.0. Each electronic invoice must comply with European standard EN 16931-1 :2017 and one of the following two syntaxes:
- XML UBL (Universal Business Language);
- XML UN/CEFACT CII (Cross Industry Invoice).
B2G eInvoices are exchanged via the Peppol network which can also, by default, be used by enterprises for B2B exchange.
Monitoring mechanism
Monitoring is done via exploiting statistics from the 2 most important access points, the one of CTIE and the one of SIGI and additionally via the Peppol reporting that makes it mandatory for all Peppol service providers from January 2024 on to provide detailed statistics on the number of messages sent and received, on the number of senders and recipients, on the types of messages, etc. to the non-profit association OpenPeppol and to the Peppol Authorities. More than 760 public sector bodies are connected to Peppol in June 2024, and in 2023 more than 1 million electronic invoices were received via Peppol in Luxembourg. More than 1 100 private sector bodies are also already receiving messages via Peppol.
Use of Core Invoicing Usage Specifications (CIUS) at national level
In Luxembourg, it is mandatory for all public sector bodies to be able to receive electronic invoices via the Peppol network. Hence Luxembourg is using Peppol’s CIUS. No specific national CIUS has been implemented or is planned to be implemented.
Digital reporting requirements
In Luxembourg, eInvoicing is not currently used for Valued Added Tax (VAT) digital reporting. However, while no reporting obligation has been introduced, accounting and tax data in SAF-T format can be requested from certain companies by tax authorities in the case of audits. These on-demand requests linked to audits are not considered as Digital Reporting Requirements (DRRs)[3].
Additional information
The national strategy in the medium and long term includes using Peppol beyond pure eInvoicing (e.g., eOrder, Invoice response, Message response, etc.), allowing for the exchange of new document types via Peppol on a national level, developing B2B eInvoicing and starting to use eInvoicing for digital VAT reporting.
[1] (Electronic Invoicing in Luxembourg, 2021), [2] (Electronic invoice), [3] (VAT in the Digital Age Report Digital Reporting Requirements, 2022)
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Last updated: Jun 28, 2024 18:13