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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. eInvoices in B2G public procurement are used volontarily by suppliers. Receiving and processing of compliant eInvoices are mandatory for central public sector bodies as of 18 April 2019. Sub-central entities are mandated to receive and process compliant eInvoices as of 18 April 2020.

eInvoicing platform and eInvoicing management solutions

In Luxembourg, eInvoices are submitted and processed using a central PEPPOL access point as well as sector-specific dispatching and accounting solutions. The maintenance of the PEPPOL access point is outsourced by the Government IT Centre to an external service provider. According to the eInvoicing programme of the Luxembourgish government, the PEPPOL access point is to be used by all central government organisations and can also be used by local organisations, given that they integrate PEPPOL with their accounting systems. They would have to individually integrate the PEPPOL access point as currently the accounting back office of the government is not used by the local municipalities and only available for the central government.

Approach for receiving and processing eInvoices

Economic operators can submit eInvoices via the PEPPOL network using the PEPPOL-BIS and UBL 2.1 eInvoicing standards. Luxembourg will also, in the future, accept the upload of compliant eInvoices via a web form, thus offering a possibility not to use PEPPOL for eInvoices that would not use the PEPPOL CIUS or another syntax than UBL. Furthermore a web form allowing to insert the content of an invoice manually and to submit it afterwards via the form will also be offered. For the moment, the contracting authorities usually still process the eInvoices manually.

The eInvoicing programme of the Luxembourgish government foresees the integration of eInvoices with the government’s accounting system intending to automate as far as possible the eInvoicing submission, processing and payment process. 

eInvoicing implementation in sub-central level contracting authorities 

The municipalities have still to decide if they will use the central PEPPOL access point or if they will create their own PEPPOL access point that will then be used by all or most of them.

Nowadays, eInvoicing is still nearly not used at the sub-central level.

Status on the implementation of the European Standard on eInvoicing (EN)

As the PEPPOL network and a PEPPOL access point are used, the EN is also used as the PEPPOL mandatory BIS version 3.0 standard is compliant to the EN. The EN can, therefore, be considered as implemented.

Monitoring eInvoicing implementation 

There is a monitoring strategy in place only at the central level. This is because the sub-central level has only to comply with the requirements of the law from 18 April 2020 onward. In light of this, likely the monitoring will also take place at sub-central level soon. In this case, a central tool managed by the SIGI (IT Centre of the municipalities) will probably be used.

The units of measurement are the number of suppliers using eInvoicing, the number of invoices that are submitted electronically and the number of eInvoices submitted in a specific syntax.

At the time of publication of this factsheet, the number of suppliers using eInvoices is lower than 5 and less than 1% of the invoices received are eInvoices. 

PEPPOL only accepts the UBL syntax. Therefore, in principle, 100 % of the eInvoices use UBL.

Use of Core Invoicing Usage Specifications (CIUS) at national level  

Luxembourg is using a PEPPOL access point for the whole government and, therefore, they are using PEPPOL’s CIUS. No specific national CIUS has been implemented or is planned to be implemented.

Additional information

The short term onboarding strategy is to liaise with private enterprises, to raise awareness and convince them of sending compliant eInvoices. The definition of a detailed strategy and action plan is ongoing and will be finalised in the next months.

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