Luxembourg suppliers to public bodies have sent structured e-invoices since 2023. Bill No 8815, filed in July 2026, would oblige Luxembourg businesses to receive structured B2B invoices from 1 January 2028 and to issue them from 1 July 2028 or 1 January 2029, by size. The Netherlands plans domestic and intra-EU B2B e-invoicing from 1 July 2030 and domestic reporting from 2031. ViDA, already EU law, makes intra-EU B2B e-invoicing within ten days and transaction reporting mandatory from 1 July 2030. Belgian customers have been on Peppol since January 2026.
The PDF invoice has a known end date in the Benelux
An e-invoice in the legal sense is not a PDF attached to an email. It is a structured data file, built to the European standard EN 16931, that the customer's software reads and books without anyone retyping it. The PDF is a picture of an invoice. The e-invoice is the invoice itself, as data.
Public buyers in Luxembourg and the Netherlands have required this format for years. What is new is business-to-business invoicing. Belgium switched on 1 January 2026. Luxembourg filed a bill in July 2026 to follow from 2028. The Netherlands announced in September 2026 that it intends to follow in 2030. Behind all three sits the EU's VAT in the Digital Age package, ViDA, which makes structured e-invoicing and transaction-level reporting compulsory for intra-EU business sales from 1 July 2030.
Three questions decide the work: must you send structured invoices, must you be able to receive them, and from when. Belgium is covered in a separate note on e-invoicing in Belgium and ViDA; here it matters only as a cross-border driver.
Since 2023
All suppliers to public bodies since 18 March 2023.
2028 to 2029
Bill No 8815: receive, then issue.
July 2030
Government plan, consultation pending.
1 July 2030
Intra-EU B2B e-invoicing and reporting.
ViDA: what is already law and what applies from 2030
Council Directive (EU) 2025/516 of 11 March 2025 amends the VAT Directive in three pillars: digital reporting and e-invoicing, the platform economy, and single VAT registration. It was published in the Official Journal on 25 March 2025 and entered into force on 14 April 2025.
Already in effect. Since entry into force, a member state no longer needs an EU derogation to impose domestic e-invoicing on businesses established in its territory. That change is why Belgium, Luxembourg and the Netherlands can now legislate on their own timetable. The directive also makes the structured invoice in EN 16931 the default meaning of 'electronic invoice'; a PDF no longer qualifies once a member state switches.
From 1 July 2030. For intra-EU supplies of goods and for cross-border services where the customer accounts for the VAT under the reverse charge, the supplier must issue a structured e-invoice within ten days of the chargeable event. The invoice data must be reported to the supplier's tax administration within the same window, and the recapitulative statement (the EC Sales List in English usage, the ICP listing in Dutch, the état récapitulatif in Luxembourg) is replaced by these transaction-level reports. Member states may require the customer to report too. Summary invoices remain possible, once a month per customer.
| Date | What changes | Status |
|---|---|---|
| 14 April 2025 | Member states may impose domestic B2B e-invoicing without derogation | In force |
| 1 July 2028 | Single VAT registration and platform rules (other ViDA pillars) | Adopted |
| 1 July 2030 | Intra-EU B2B: structured e-invoice within 10 days and digital reporting; recapitulative statements end | Adopted |
| By 2035 | National reporting systems to converge with the EU model | Adopted |
The 2030 rule applies whatever a member state does domestically: a Luxembourg SARL selling consulting to a German GmbH needs a structured invoice from July 2030 even if Luxembourg's own regime slipped. Every business buying across borders will need a receiving channel by then.
Law and practice: Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age, OJ L of 25 March 2025; Directive 2014/55/EU on electronic invoicing in public procurement; standard EN 16931-1:2017. European Commission, Taxation and Customs Union, 'VAT in the Digital Age'.
Public buyers since 2023, businesses from 2028 under bill No 8815
Public sector, now. The Law of 16 May 2019 on electronic invoicing in public procurement and concession contracts, as amended by the Law of 13 December 2021, obliges every supplier of a Luxembourg public body to send structured e-invoices, whatever the amount. The obligation was phased in by size: large operators from 18 May 2022, medium-sized from 18 October 2022, small and newly created operators from 18 March 2023. Since then it applies to all. Peppol is the common delivery network; suppliers with a handful of public invoices can use the two manual forms on MyGuichet.lu instead.
The law sets no specific fine for a PDF sent to a public buyer. The sanction is practical: the body rejects the invoice, and the payment clock does not start until a compliant one arrives.
Businesses, from 2028. On 30 July 2026 the government filed bill No 8815, with a draft Grand-Ducal regulation, extending the regime to domestic B2B invoices between taxable persons established in Luxembourg, where the supply is taxable in Luxembourg. The recipient's consent, required today for any electronic invoice, would no longer be needed. Credit notes correcting a compliant e-invoice must be structured too.
| Step under bill No 8815 | Date | Who |
|---|---|---|
| Able to receive and process compliant e-invoices | 1 January 2028 | All in-scope businesses |
| Issue and transmit compliant e-invoices | 1 July 2028 | Large and medium-sized businesses |
| Issue and transmit compliant e-invoices | 1 January 2029 | Small businesses, and those without 2026 figures |
| Intra-EU B2B e-invoicing and digital reporting (ViDA) | 1 July 2030 | All, under EU law |
Size is tested once, on the 2026 balance sheet, entity by entity. A business is large or medium-sized if it exceeds two of three thresholds: EUR 7.5 million balance-sheet total, EUR 15 million net turnover, 50 full-time employees on average. Two companies in one group can therefore have different start dates.
Exclusions and low volumes. Ordinary sales to consumers stay outside, as do transactions that need no invoice under Article 63 of the VAT law, such as exempt insurance and fund management services. Suppliers neither established nor VAT-registered in Luxembourg are outside. A permanent low-volume route on MyGuichet.lu is planned: free up to 75 issued and 150 received invoices a year, then a usage fee per invoice rising from EUR 2 to EUR 5. Free transitional receiving through MyGuichet.lu would run until 30 June 2028, or 31 December 2028 for small businesses. All of this is still a bill.
Unchanged rules. The invoicing deadline stays the 15th day of the month after the chargeable event. Invoices and the structured files are kept for ten years. On a VAT audit the AED can ask for the FAIA, Luxembourg's version of the OECD Standard Audit File for Tax, an export of the accounting data; businesses with turnover up to EUR 112,000 or about 500 entries a year are excused. For registrations and returns see our note on VAT registration in Luxembourg.
A Luxembourg IT SARL with 12 staff wins a two-year contract with a ministry: EUR 8,000 a month plus 17% VAT, so EUR 9,360 per invoice and 24 invoices over the contract. The SARL's accounting software has a Peppol module, so it registers its VAT number on the network and issues each monthly invoice in Peppol BIS Billing 3.0, quoting the purchase order reference the ministry gave it. If the software had no module, 24 invoices over two years would fit comfortably within the manual MyGuichet.lu form. For its private customers, the same SARL would have to receive structured invoices from 1 January 2028 and, as a small business on its 2026 figures, issue them from 1 January 2029, if the bill passes as filed.
Law and practice: Law of 16 May 2019 on electronic invoicing in public procurement and concession contracts, amended by the Law of 13 December 2021; Grand-Ducal Regulation of 13 December 2021; bill No 8815 of 30 July 2026 amending the 2019 law and the VAT law of 12 February 1979; VAT law, Articles 61 to 63 and 70. Sources: efacturation.public.lu; gouvernement.lu, 'Electronic invoicing in Luxembourg'; PwC Luxembourg and KPMG Luxembourg notes of July and August 2026; Chambre de Commerce, 'VAT FAIA'.
Public buyers already, businesses from 2030 under a government plan
Public sector, now. Dutch central government began requiring e-invoices from suppliers under new purchase contracts from 1 January 2017. Since the Public Procurement Act was amended to transpose Directive 2014/55/EU, all contracting authorities must be able to receive and process EN 16931 invoices; the European Commission's country sheet gives 2019 for full coverage. The supplier's duty is mainly contractual. The Dutch customisation is NLCIUS, implemented as SI-UBL 2.0, and Peppol BIS Billing 3.0 is accepted too. Suppliers send through Peppol, through Digipoort or, at low volumes, through the government's supplier portal.
Businesses, from 2030: a plan, not yet a bill. In a letter to Parliament of 11 September 2026 the State Secretary for Finance set out a broad implementation of ViDA. The intended timetable is below. The draft bill is to go to public consultation on internetconsultatie.nl in autumn 2026, reach the House of Representatives before summer 2027, and complete the parliamentary process within about a year.
| Intended date | Obligation | Status |
|---|---|---|
| 1 July 2030 | Domestic and intra-EU B2B: issue and receive structured e-invoices | Government plan |
| 1 July 2030 | Digital reporting of intra-EU B2B transactions, at invoice level | EU law (ViDA) |
| 1 July 2031 | Digital reporting of domestic B2B transactions | Government plan |
| Autumn 2026 | Internet consultation of the draft bill | Planned |
The plan follows EN 16931 with no extra Dutch format. The delivery network is open: Peppol and the European Business Wallet are both mentioned. Businesses using the small business scheme (KOR), with turnover up to EUR 20,000, would be excluded; no other new exemption is planned. Invoices would generally have to be issued within ten days of the supply, as under ViDA. Until the law changes, the Dutch deadline remains the 15th day of the month after the supply, and an electronic invoice still needs the customer's acceptance.
Records. Dutch tax law requires most business records to be kept for seven years; data on immovable property for ten. Our note on Dutch VAT registration covers numbers, returns and Article 23 import deferment.
Not the same topic: SBR. Dutch companies file annual accounts in XBRL through Standard Business Reporting. That is digital filing of statements, not invoicing. For the annual cycle see the Dutch B.V. compliance calendar.
Law and practice: Dutch Public Procurement Act 2012 as amended to transpose Directive 2014/55/EU; Dutch VAT Act 1968, Article 35a (invoicing); General State Taxes Act, Article 52 (record keeping). Letter of the State Secretary for Finance of 11 September 2026 on ViDA implementation; Belastingdienst, 'Hoe lang moet u uw administratie bewaren'; European Commission, 'eInvoicing in the Netherlands'; Grant Thornton Netherlands and KPMG notes of September 2026.
Why Belgian customers already want Peppol from you
Since 1 January 2026 VAT taxpayers established in Belgium must issue and receive structured e-invoices for domestic B2B supplies, in practice through Peppol. Penalties run from EUR 1,500 for a first breach to EUR 5,000 for repeated breaches, and Belgian e-reporting of invoice data follows from 2028. The full picture is in our Belgium e-invoicing note.
For Luxembourg and Dutch companies the mandate works indirectly. A company with only a Belgian VAT number and no establishment there is outside it for now. A company with a Belgian branch involved in the supply is inside. A Dutch or Luxembourg company selling to Belgian businesses from home is not obliged to send Peppol invoices, but every Belgian customer is now on Peppol and expects to receive through it.
A Rotterdam B.V. sells spare parts to 30 Belgian workshops, about 40 invoices a month averaging EUR 1,250 net, so EUR 50,000 a month. These are intra-EU supplies of goods: zero-rated, with the Belgian VAT number of each customer on the invoice and the totals in the Dutch ICP listing. The Belgian mandate does not apply to the B.V., because it has no Belgian establishment. But by spring 2026 eleven customers ask for Peppol invoices, two state that PDFs will be paid late, and one rejects invoices without its Belgian company number. The B.V. activates Peppol in its accounting software, at a subscription cost that its provider sets, and sends all Belgian invoices in Peppol BIS Billing 3.0 from June 2026. The same set-up covers its ViDA obligation for these sales from 1 July 2030, when the ICP listing gives way to transaction reports. Had it opened a Brussels sales branch involved in the supplies, the Belgian mandate would have applied directly from 2026.
Law and practice: Belgian Law of 6 February 2024 introducing mandatory B2B e-invoicing from 1 January 2026; Belgian VAT Code, Article 53 and Royal Decree No 44 on penalties; FPS Finance, einvoicing.belgium.be.
Sending, receiving, holdings, self-billing, archiving and cost
Peppol in one paragraph. Peppol is a network of certified access points. You connect to one, either through your accounting software or a specialist provider, and are listed in a directory under an identifier such as your VAT or company number. A supplier's access point looks you up and delivers the invoice to yours. Each side pays only its own provider.
Receiving comes before sending. A company that sends ten invoices a month may receive two hundred. Under the Luxembourg bill every in-scope business must be able to receive from 1 January 2028, a full six months before the first issuers.
Holdings and VAT-exempt entities. A passive holding that only holds shares is not a taxable person. It issues no VAT invoices, so issuing rules do not touch it. It may still be identified for VAT to self-account for services bought from abroad. Whether such a holding counts as an in-scope recipient under bill No 8815 is not settled; the free MyGuichet.lu receiving route covers the volumes involved. A holding that charges management fees is a taxable person for those services; see our note on Luxembourg holding VAT and management fees.
VAT groups. Supplies within a VAT group are outside the scope of VAT and need no invoice. The group's supplies to outsiders and purchases from them do, and each member keeps its own Peppol identity in practice.
Self-billing, credit notes, foreign suppliers. Self-billing remains possible where agreed in advance: the customer issues the structured invoice for the supplier. Credit notes follow the invoice they correct, so a structured invoice is corrected by a structured credit note. Suppliers from outside Luxembourg or the Netherlands are not bound by those countries' domestic mandates, though intra-EU suppliers will be bound by ViDA from 2030.
| Item | Luxembourg | Netherlands |
|---|---|---|
| Public buyers | Mandatory for all suppliers since 18 March 2023 | Contractual since 2017; all authorities receive |
| Domestic B2B | Receive 2028, issue 2028 or 2029 (bill) | Issue and receive 1 July 2030 (plan) |
| Domestic reporting | Not yet defined | 1 July 2031 (plan) |
| Invoice deadline today | 15th of the following month | 15th of the following month |
| Retention | 10 years | 7 years; 10 for immovable property |
| Small business carve-out | Free low-volume MyGuichet.lu route (bill) | KOR, turnover up to EUR 20,000 (plan) |
Penalties. Belgium has fixed amounts. Luxembourg's public regime has none beyond rejection, and bill No 8815 relies on the general VAT penalty rules. The Dutch plan does not yet specify sanctions. In all three, the practical risk is the same: a non-compliant invoice is not a valid invoice, and the customer's input VAT deduction can be challenged.
Implementation steps.
- Map flowsList customers and suppliers by country and type: public, domestic B2B, Belgian, other EU, consumers.
- Check softwareAsk your provider whether Peppol sending and receiving are included and in which formats.
- Clean master dataVAT numbers, company numbers, addresses, purchase order references.
- RegisterPut your identifiers in the Peppol directory and tell customers and suppliers.
- ArchiveStore the XML itself for ten years in Luxembourg, seven in the Netherlands.
Cost depends on volume. Cloud accounting packages often include Peppol; an ERP needs an access point contract and mapping work.
A Luxembourg SOPARFI holds shares in two subsidiaries and has no turnover. It is identified for VAT only to self-account for services bought abroad. A Dutch firm invoices it EUR 3,000 a quarter for accounting services, EUR 12,000 a year. The Dutch firm charges no Dutch VAT; the SOPARFI self-accounts for 17% Luxembourg VAT, EUR 2,040 a year, and cannot deduct it. Today the invoice can be a PDF. From 1 July 2030 it falls under ViDA as a reverse-charge supply between member states, if the SOPARFI is treated as a business customer: the Dutch firm must issue a structured invoice within ten days and report it. The SOPARFI then needs a way to receive and to keep the XML for ten years. With four invoices a year, a free MyGuichet.lu account or a basic Peppol mailbox is enough. For running costs generally, see holding running costs.
Law and practice: Peppol BIS Billing 3.0 (OpenPeppol); Luxembourg VAT law, Articles 60bis (VAT groups), 63 and 70; Dutch VAT Act 1968, Article 35 (self-billing); Council Directive (EU) 2025/516 on reverse-charge supplies from 2030. The status of non-taxable holdings as recipients under bill No 8815 depends on the final text.
Check your e-invoicing timeline
Choose where your company is established, its VAT status, its customers and its invoice volume. The checker lists what applies today, what follows from adopted EU law and what is still a Luxembourg bill or a Dutch plan, with dates counted from today. It is a first orientation, not an opinion on your company.
E-invoicing: what applies to you, and when
Five questions. You get the obligations that already apply, those that follow from adopted EU law and those still at the bill or proposal stage, with dates counted from today, whether you must send, receive or both, and the steps to take first.
Luxembourg public buyers: structured e-invoices from all suppliers.
Luxembourg B2B receiving, then issuing, under bill No 8815.
ViDA intra-EU e-invoicing; Dutch domestic plan.
Suppliers switch before you do.
E-invoicing in Luxembourg and the Netherlands: frequent questions
Is a PDF invoice sent by email an e-invoice?
Not for the new rules. A compliant e-invoice is structured data, usually an XML file in the European standard EN 16931, that software can read without a person typing it in. Public buyers in both countries already require it.
When does B2B e-invoicing become mandatory in Luxembourg?
Under bill No 8815, filed on 30 July 2026 and not yet adopted, Luxembourg businesses must be able to receive structured e-invoices from 1 January 2028. Large and medium-sized businesses must issue them from 1 July 2028 and small businesses from 1 January 2029.
When does it become mandatory in the Netherlands?
The Dutch government announced on 11 September 2026 that it intends to require e-invoicing for domestic and intra-EU B2B transactions from 1 July 2030, with digital reporting of domestic transactions from 1 July 2031. It is a policy plan: the draft bill goes to public consultation first and should reach Parliament before summer 2027.
Does a Luxembourg holding without turnover have to do anything?
A pure holding that is not a taxable person issues no VAT invoices, so the issuing obligations do not bite. Whether it must be able to receive structured invoices under the Luxembourg bill depends on the final text; a holding with a VAT number for reverse-charge purposes should plan for a free low-volume receiving solution at the least.
How long must I keep e-invoices?
Ten years in Luxembourg. Seven years in the Netherlands for most records, ten years for data on immovable property. Keep the structured file itself, not only a printout, with its integrity and readability guaranteed.