E-invoicing grant in Luxembourg: 70% of the project
The e-invoicing grant in Luxembourg exists, but it cannot be claimed after the fact: the application is filed before the first euro is committed.
Is there an e-invoicing grant in Luxembourg?
Yes: the e-invoicing grant in Luxembourg runs through SME Packages – Digital, a Ministry of the Economy scheme covering 70% of the eligible costs of a project worth between EUR 3,000 and EUR 25,000 excluding VAT, on condition that the application is filed before the work starts.
The scheme is not specific to electronic invoicing. It belongs to a family of packages aimed at small and medium-sized enterprises, each covering a distinct field. The Digital, Sustainability, Service and Starter Kit RSE strands already existed; two further fields, AI and Cybersecurity, were announced on 11 March 2025 by the Minister of the Economy Lex Delles. The same announcement raised the aid intensity to 70% of eligible costs, for projects of EUR 3,000 to EUR 25,000 excluding VAT.
Two points decide the rest. The aid is a reimbursement, paid once the solution is in place rather than on order. And the file is not one you complete alone: it is prepared with an adviser from the House of Entrepreneurship of the Chamber of Commerce, or from the eHandwierk department of the Chamber of Skilled Trades and Crafts for a craft business.
| Package | Field covered | Vintage |
|---|---|---|
| SME Packages – Digital | Digital marketing, management systems, electronic invoicing | Predates March 2025 |
| SME Packages – Sustainability | Reducing the environmental impact of the business | Predates March 2025 |
| SME Packages – Service | Improving the customer experience | Predates March 2025 |
| Starter Kit RSE | Corporate social responsibility approach | Predates March 2025 |
| SME Packages – AI | Assessing the current position and integrating artificial intelligence tools | Announced on 11 March 2025 |
| SME Packages – Cybersecurity | Cybersecurity level, NIS2 compliance, technologies and procedures | Announced on 11 March 2025 |
Who can apply for SME Packages – Digital?
SME Packages – Digital is open to a business established in Luxembourg that holds a business permit and meets the definition of a small or medium-sized enterprise, assessed on three elements: headcount, annual turnover and annual balance sheet total.
Those three elements are not read in the same way. Headcount must stay below 250 people, and that condition always applies. For the two financial criteria, meeting either one is enough: annual turnover not exceeding EUR 50 million, or an annual balance sheet total not exceeding EUR 43 million. The scheme carrying those thresholds is the law of 9 August 2018 on an aid scheme for small and medium-sized enterprises, which implements certain provisions of European regulation 651/2014 of 17 June 2014.
The trap lies in the perimeter applied. It is not enough to look at the applicant alone: the figures of any other economic entity with which it forms a single economic unit count too. A modest subsidiary held by a group well above the thresholds is not an SME for the purposes of the scheme, and that is established when the file is examined.
Sector exclusions complete the picture and apply across the scheme: fisheries and aquaculture, primary agricultural production, and the processing and marketing of agricultural products, with exceptions depending on the type of aid. A Luxembourg service company falls under none of them.
| Criterion | Threshold | How it applies |
|---|---|---|
| Headcount | Fewer than 250 people | Required in every case |
| Annual turnover | EUR 50 million at most | Either financial criterion is enough |
| Annual balance sheet total | EUR 43 million at most | Either financial criterion is enough |
| Perimeter assessed | Entities forming a single economic unit | Headcount and financial figures assessed together |
| Business permit | Held by the applicant company | Precondition for any aid under the scheme |
What does the e-invoicing strand of the package fund?
The electronic invoicing strand of SME Packages – Digital funds, in Luxembourg, the deployment of a management system fitted with an electronic invoicing module, implemented by a service provider. It sits in the same package as digital marketing and management systems.
Digital marketing covers creating or improving a website and running social media campaigns. Management systems cover a point-of-sale system, software specific to a line of business, or an enterprise resource planning suite. The third field covers the electronic invoicing module attached to that kind of system.
What the package funds is not a change of invoice template. An electronic invoice within the meaning of the applicable texts is a document issued, transmitted and received in a structured electronic form allowing automatic processing, that is, an XML file or a file containing XML, rather than an unstructured PDF or word-processing document. It is that structure which calls for accounting software able to produce and receive the expected format.
Two neighbouring steps fall elsewhere. Connecting to the delivery network and publishing the identifier, set out in our article on the Peppol directory, are technical operations distinct from the funding described here. And the Fit 4 Digital programme, run by Luxinnovation, funds a digital maturity diagnosis with a costed action plan, which is not a deployment.
How much does the company still bear?
On an eligible electronic invoicing project in Luxembourg, the grant covers 70% of the costs retained and the company bears the remaining 30%: the highest reimbursement reaches EUR 17,500, on a quote at the ceiling of EUR 25,000 excluding VAT.
The mechanics are those of a reimbursement and deserve to be planned for. The company chooses its package and its provider, agrees a quote within the range, has the file validated, then settles the invoice. The subsidy of 70% of eligible costs is paid by the Ministry of the Economy once the solution is in place. Between committing the spend and receiving the aid, the company's cash carries the full cost.
VAT is handled separately. The limits of the scheme are stated excluding value added tax: the tax charged by the provider is not part of the aid base. For a taxable person with a full right of deduction the question is neutral; for an exempt activity without a right of deduction, that VAT is a real and unsubsidised cost.
One last rule limits the stacking of schemes. A single project cannot combine different State aids bearing on the same costs, unless the maximum intensity ceiling of the schemes concerned is still respected.
| Provider's quote | Aid at 70% | Borne by the company, excluding VAT |
|---|---|---|
| EUR 2,500, below the floor | No aid, project outside the scheme | The whole quote |
| EUR 3,000, at the floor | EUR 2,100 | EUR 900 |
| EUR 10,000 | EUR 7,000 | EUR 3,000 |
| EUR 25,000, at the ceiling | EUR 17,500 | EUR 7,500 |
| EUR 30,000, above the ceiling | Capped, eligible costs limited | The balance above the ceiling |
How does the application work, step by step?
An application in Luxembourg starts with an appointment at the House of Entrepreneurship of the Chamber of Commerce, or at the eHandwierk department of the Chamber of Skilled Trades and Crafts for a craft business, for a pre-analysis of where the company stands on digitalisation.
What follows runs in five stages. The company picks the package and the provider that fit its need, and agrees with that provider a quote inside the eligible range. The House of Entrepreneurship and eHandwierk teams assist in preparing the file. The Ministry of the Economy analyses and validates it. The provider then implements the tool, and an evaluation meeting takes place once implementation is complete. The company settles the invoice, then receives the subsidy.
The order of events is not a procedural detail: the application must be filed before the work starts. A project already ordered, already committed or already invoiced cannot be rescued by a file submitted afterwards.
On supporting documents, a payment claim for State aid to businesses requires the items that let the competent minister assess the qualities and specifics of the project: invoices, proof of payment — a bank statement, for instance — and the file, report or result of the provider's assignment.
| Stage | Who acts | What happens |
|---|---|---|
| 1. Pre-analysis | House of Entrepreneurship or eHandwierk | Review of digitalisation and priority actions |
| 2. Quote | Company and provider | Package and provider chosen, quote inside the range |
| 3. File | Adviser, with the company | Application prepared, before the work starts |
| 4. Examination | Ministry of the Economy | Application analysed and validated |
| 5. Implementation | Provider | Tool deployed, then evaluation meeting |
| 6. Payment | Company, then ministry | Invoice settled, documents filed, subsidy paid |
Which mistakes forfeit the grant?
The most frequent mistake in Luxembourg is signing the provider's quote before filing the aid application: the application must predate the start of the work, and no later regularisation restores that order.
We see the same sequence regularly on engagements. A director takes the renewal of a management tool as the moment to add an electronic invoicing module, signs the quote straight after a demonstration, then discovers the scheme while preparing the year-end close. The project is sound, the provider is sound, and the spend is lost for grant purposes. The order of the steps matters as much as their content.
Three further points are worth checking before committing. The quote must stay inside the range. The group perimeter must be assessed honestly, since a single economic unit above the thresholds removes SME status. And proof of payment must be kept from the first invoice onwards, which assumes bookkeeping kept as you go rather than reconstructed at the year end.
A word, finally, on the nature of the advice. The pre-analysis and the preparation of the file belong to the professional chambers, the examination to the Ministry of the Economy. Our role is limited to documenting the spend, producing the accounting records requested and holding the timetable: we decide neither eligibility nor the amount awarded.
Should you wait for the B2B obligation before starting?
Nothing requires waiting in Luxembourg: the obligation to issue electronic invoices to the public sector has applied to every economic operator since 18 March 2023, whatever its size, while the business-to-business leg is still only a text filed with Parliament.
The public leg is therefore settled law. A supplier invoicing a public sector body under a public procurement or concession contract must transmit a compliant electronic invoice through an authorised channel, regardless of the amount invoiced. We set out that framework in our article on public sector e-invoicing obligations.
The business-to-business leg remains at the parliamentary stage. Bill 8815 was filed on 30 July 2026 and referred to the Finance Committee; no entry into force is asserted here, and our article on the B2B e-invoicing bill follows the state of the file. The calendar argument does not favour waiting: a scheme whose parameters already moved in March 2025 can move again.
To place the scheme in scale, the Ministry of the Economy presented on 2 July 2025 its review of aid granted in 2024: 1,238 projects of small and medium-sized enterprises supported under the law of 9 August 2018, for EUR 25 million of aid granted and EUR 153 million of investment generated. That figure covers the whole scheme, not SME Packages – Digital alone.
Sources and verification
Written for Financial Services Luxembourg and reviewed before publication by Mickaël LOC, licensed accountant (authorisation 10077274). The rates, limits, eligibility conditions, procedural stages and dates cited here were verified on 18 September 2026 against the official sources listed below.
On guichet.public.lu: the SME Packages scheme page devoted to SME Packages – Digital, for the three fields of the package, for the aid of 70% of eligible costs granted by the Ministry of the Economy, for the range of EUR 3,000 to EUR 25,000 excluding VAT, for the business permit and SME status conditions, for the pre-analysis by the House of Entrepreneurship or the eHandwierk department, for the five-stage sequence through to the evaluation meeting, for reimbursement after implementation, and for the requirement that the application predate the start of the work; the sister pages of the Service, AI, Sustainability and Cybersecurity packages, for the identity of the limits and the rate from one package to another; the news item of 11 March 2025 on the new packages and the change in aid intensity; the general conditions page for general SME aid, for the headcount below 250 people, for annual turnover of at most EUR 50 million or an annual balance sheet total of at most EUR 43 million, for either financial criterion being sufficient, for the single economic unit test, for the sector exclusions, for the rule against combining aid on the same costs beyond the maximum intensity, and for the scheme resting on the law of 9 August 2018 and European regulation 651/2014; the page on payment claims for State aid to businesses, for the invoices, proof of payment and result of the provider's assignment; the Fit 4 Digital programme page, for the diagnosis run by Luxinnovation. On the government side: the communiqué of 11 March 2025 announcing the launch of two new SME Packages, and that of 2 July 2025 on the review of State aid granted in 2024, for the 1,238 projects supported, the EUR 25 million granted and the EUR 153 million of investment generated. On legilux.public.lu: the law of 9 August 2018. On cc.lu: the Chamber of Commerce e-invoicing thematic file and its frequently asked questions, for the definition of an electronic invoice as a structured XML file as opposed to an unstructured PDF.
Five points could not be verified. The pages of guichet.public.lu, gouvernement.lu and legilux.public.lu are unreachable from our drafting environment: they were consulted through indexed extracts, so no article numbering of the law of 9 August 2018 is cited here, and neither is the date on which the package page was last updated. Whether the pre-analysis is free of charge could not be established. The ministry's processing time, and the period within which the payment claim must be filed, appear on no source consulted. Whether a fiduciary may itself be the paid provider of the package could not be settled. Lastly, the Chamber of Commerce FAQ mentions a flat subsidy of EUR 5,000 for a system with an electronic invoicing module: a secondary source, of undetermined date, possibly predating the March 2025 increase, and confirmed by no official page consulted. Readers can confirm these points on guichet.public.lu, with the House of Entrepreneurship or eHandwierk, and with the Ministry of the Economy.
This article states the law as it stands at the date of publication. Aid schemes, their rates and their limits change, and any decision binding your structure must be checked on the date you rely on it. Report an error to contact@financialservices.lu: the correction is dated in the article.
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