Luxembourg (2021 eInvoicing Country Sheet)

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. In B2G public procurement, eInvoices are used voluntarily 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. 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[1]. 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 Peppol BIS Billing 3.0 and UBL 2.1. Luxembourg will also, in the future, accept the upload of EN-compliant eInvoices via a web form, thus offering an alternative to 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 eInvoices will be available. For the moment, the public 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. 

Within the B2G context, all public contracting authorities are mandated for receiving, while no explicit requirements exist for the issuing. Within the B2B environment, eInvoices are allowed, however the buyer’s consent is needed for receiving[2].

No electronic signature is required for eInvoices and the archiving period amounts to 10 years, however archiving abroad is allowed under conditions[3]. Namely, archiving abroad is allowed in EU countries or other tax assistance treaty countries subject to notification and online access[4].

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 an Access Point exclusively for transactions with sub-central public entities.

Nowadays, the adoption of eInvoicing at the sub-central level is limited, due to the lack of eInvoicing adoption from public contracting authorities’ suppliers.

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 and UBL 2.1. B2G eInvoices are shared via the Peppol network. 

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 since 18 April 2020. 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.

In 2020, the number of suppliers using eInvoices is lower than 5 and less than 1% of the invoices received are eInvoices. 

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. 

[1] (List of countries for your e-invoicing requirements, 2021), [2] (Compliance updates Luxembourg, 2021), [3] (Compliance updates Luxembourg, 2021), [4] (E-Invoicing Compliance - One Global Solution, 2021)

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Last updated:  Jun 29, 2021 12:03