Luxembourg B2B E-Invoicing Mandate Draft Law 2026

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Flick team

Last updated at

July 24, 2026

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Luxembourg E-Invoicing Mandate: Domestic B2B Extension Proposed

Luxembourg's Council of Government approved a draft law on 17 July 2026 that extends mandatory e-invoicing beyond public procurement contracts. The new legislation, once adopted, will require domestic business to business (B2B) transactions between companies established in Luxembourg to move to electronic invoicing. This update covers the scope of the draft law, its link to the EU's VAT rules, and what businesses in Luxembourg should track before the mandate takes effect.

Key Takeaways

  • Luxembourg's Council of Government approved a draft law on 17 July 2026 to expand mandatory e-invoicing.

     
  • The mandate currently applies only to public procurement and concession contracts under the 2019 e-invoicing law.

     
  • The draft law extends the obligation to domestic business to business transactions between companies established in Luxembourg.

     
  • The draft law transposes Article 1 of Council Directive (EU) 2025/516 on VAT rules for the digital era.

     
  • A draft grand-ducal regulation fixes the common delivery network and alternative technical solutions for e-invoicing.

     
  • Both texts remain in draft form and must complete Luxembourg's legislative process before taking effect.

     

Luxembourg Approves Draft Law to Expand Mandatory E-Invoicing 

The Council of Government met on Friday, 17 July 2026, under the chairmanship of Prime Minister Luc Frieden. During this meeting, the Council approved a draft law amending Luxembourg's existing e-invoicing and VAT legislation.

The draft law extends the current e-invoicing obligation to domestic transactions between companies established in Luxembourg. Alongside this draft law, the Council also approved a draft grand-ducal regulation covering the technical infrastructure needed for the expanded mandate.

Current E-Invoicing Requirements in Luxembourg 

Luxembourg introduced mandatory e-invoicing through the law of 16 May 2019, which applies to public procurement and concession contracts. Under this existing framework, companies supplying goods or services to public administrations must issue electronic invoices.

The obligation does not currently extend to transactions between private companies operating within Luxembourg. The draft law approved on 17 July 2026 closes this gap by extending the obligation to those domestic transactions. 

How the Draft Law Expands Luxembourg's E-Invoicing Mandate 

The draft law approved by the Council amends two existing pieces of legislation to broaden the e-invoicing mandate. It extends the obligation, which currently applies only to public procurement and concession contracts, to domestic transactions between companies established in Luxembourg.

This extension accounts for recent developments in the European legal framework, particularly Directive 2025/516. The amendment also aims to encourage further modernisation of administrative and financial processes across Luxembourg businesses.

The draft law amends the following legislation:

  • The 2019 e-invoicing law (16 May 2019), which currently covers public procurement and concession contracts.

     
  • The 1979 VAT law (12 February 1979), updated to transpose Article 1 of EU Directive 2025/516 on VAT rules for the digital era.

     

How Luxembourg's E-Invoicing Proposal Aligns with EU VAT in the Digital Age

The draft law transposes Article 1 of Council Directive (EU) 2025/516, adopted by the Council of the European Union on 11 March 2025. This directive amends the EU's VAT Directive 2006/112/EC to adapt VAT rules to the digital economy.

By transposing this article, Luxembourg aligns its domestic e-invoicing framework with the EU's VAT rules for the digital era, as set out in Directive 2025/516. The Council's communiqué describes the domestic B2B extension as a new step in the digitalisation of the Luxembourg economy.

Common Delivery Network and Technical Requirements for E-Invoicing 

Alongside the draft law, the Council approved a draft grand-ducal regulation covering the technical infrastructure for e-invoicing. This regulation fixes the common delivery network and the alternative technical solutions available to businesses for issuing, transmitting, and receiving electronic invoices.

The stated purpose is to prevent senders and recipients of electronic invoices from being forced to deploy separate, non-interoperable technical solutions. This draft regulation is designed to execute the draft law once it completes the legislative process.

What's Next for Luxembourg's Domestic B2B E-Invoicing Mandate? 

The draft law extending mandatory e-invoicing to domestic B2B transactions and the draft grand-ducal regulation setting the common delivery network, both approved on 17 July 2026, remain in draft form at this stage. The draft law and the draft regulation must still complete Luxembourg's legislative process before entering into force, like other government bills.

The official communiqué does not specify an implementation date or transition period for the extended e-invoicing obligation. Businesses established in Luxembourg should monitor further updates from the government as the legislative process continues.

How the Proposed E-Invoicing Mandate Affects Businesses in Luxembourg 

The domestic B2B extension asks companies established in Luxembourg to prepare their invoicing systems for a broader mandate. Once the draft law and regulation take effect, businesses will process electronic invoices for transactions with other companies operating in Luxembourg, not government contracts alone.

The common delivery network is designed to provide interoperable technical options rather than a single proprietary system. Businesses that plan for compliant e-invoicing processes early can avoid disruption once the mandate becomes final.

Conclusion

Luxembourg's Council of Government has approved a draft law extending mandatory e-invoicing from public procurement into domestic B2B transactions. The draft law and its accompanying regulation on the common delivery network still need to complete the country's legislative process. Companies established in Luxembourg can start preparing their invoicing systems ahead of the eventual mandate. Contact sales@flick.network to get ahead of Luxembourg's e-invoicing mandate. 

FAQs

1. What does the new draft law change for Luxembourg businesses?

The draft law extends mandatory e-invoicing from public procurement and concession contracts to domestic B2B transactions between companies established in Luxembourg.

2. Has Luxembourg's domestic B2B e-invoicing mandate come into force?

The domestic B2B mandate has not come into force, since the Council of Government approved only the draft law on 17 July 2026, which still needs to complete Luxembourg's legislative process.

3. Which EU directive does the draft law align with?

The draft law transposes Article 1 of Council Directive (EU) 2025/516 of 11 March 2025, which adapts VAT rules to the digital economy.

4. What does the common delivery network regulation cover?

The accompanying draft grand-ducal regulation fixes the common delivery network and the alternative technical solutions available for issuing, transmitting, and receiving electronic invoices in Luxembourg.

5. When will the domestic B2B e-invoicing mandate take effect in Luxembourg?

The official communiqué from the Council of Government has not announced an implementation date or transition period for the new requirement.

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