Financial Services Luxembourg · licensed accountant · business permit 10077274 · RCS B213987

MANDATORY SINCE MARCH 2023 Public contracts · Peppol BIS Billing 3.0 format

Peppol invoicing in Luxembourg: who is affected,
and how to get set up in 48 hours.

If you invoice a government department, a municipality or a Luxembourg public body, a PDF has no longer been accepted since 18 March 2023. The invoice must be a structured XML file sent through the Peppol network. This page explains precisely who is affected, which format to use, what changes in 2030 with the ViDA directive, and how to activate Peppol without changing tools where that is possible.

Law of 13 December 2021 Peppol BIS Billing 3.0 Standard EN 16931 Native on Odoo 17 and 18 ViDA deadline July 2030 Activation in 2 hours

Check whether I am affected See the 5 steps

2023Obligation extended to all
since 18 March

1.4^MPeppol invoices in Luxembourg
in 2024, versus 100 in 2021

800Public bodies
connected to the network

2030ViDA deadline for
intra-Community B2B

01Who is affected 02What Peppol is 03The 5 steps 042030 deadline 05Our plans 06FAQ

Question 01

Who must issue Peppol invoices in Luxembourg?

All economic operators that invoice a public sector body under a public contract or a concession contract must issue Peppol invoices in Luxembourg, whatever the invoice amount. The obligation derives from the law of 13 December 2021, which amends the law of 16 May 2019 and transposes Directive 2014/55/EU. The rollout was staged by company size and completed on 18 March 2023. Exchanges between private companies are not yet subject to this obligation in Luxembourg.

The most common confusion concerns scope. Many managers believe that all their invoices must go through Peppol. That is not the case today. The trigger is the nature of the customer, not your own: as soon as a Luxembourg public body is the recipient under a public contract, the structured electronic invoice is required. Your other customers can keep receiving a PDF.

You are affected

Peppol is mandatory for these invoices

You invoice a ministry or a State administration
You invoice a municipality or an inter-municipal association
You invoice a Luxembourg public body
The service falls under a public contract or a concession
Whatever the amount, no minimum threshold applies
Whatever your size since 18 March 2023

You are not affected yet

PDF is still accepted for now

You only invoice private companies
You invoice individuals
Your public customers are located outside Luxembourg
But the ViDA deadline of July 2030 is getting closer
And your neighbours are moving faster than you
Anticipating costs two hours, being forced costs a migration

Official source and point of caution

The applicable framework is described by the Ministry of Digitalisation and implemented by the CTIE. The Grand-Ducal Regulation of 13 December 2021 designates Peppol as the common delivery network. Scope and deadlines are changing, notably as a result of the European reform: treat this page as an operational summary and check the text in force before any contractual commitment.

Question 02

What is Peppol, and why is a PDF not enough?

Peppol is a European network for exchanging structured business documents, run by the OpenPeppol association, that works through certified access points exchanging invoices with one another. A PDF is an image that the recipient has to read or re-enter. A Peppol invoice is an XML file that a system processes automatically, without human intervention. It is this difference in nature, and not the transmission channel, that underpins the legal obligation.

The network

Peppol connects certified access points using a four-corner model: your software, your access point, the recipient's access point, then the recipient's system. Luxembourg public bodies that do not have their own access point use the CTIE's. You do not need to know the recipient's infrastructure.

OpenPeppol
Access points
4-corner model
CTIE access point
SMP directory
Acknowledgement of receipt

The format

Peppol BIS Billing 3.0, based on the UBL 2.1 syntax and aligned with the European standard EN 16931. The same format is used in Belgium, France, Italy and Spain. A single implementation therefore covers all your European customers, which is the decisive advantage over proprietary solutions.

BIS Billing 3.0
UBL 2.1
EN 16931
Structured XML
EU interoperable
Validity checks

The identifier

Each participant has a Peppol identifier registered in the network directory, usually built from the VAT number. This identifier is what allows your invoice to find its recipient. Your access point carries out the registration, so you have no technical steps to take on your own.

Unique identifier
Based on VAT
Public directory
Registered by the AP
Verifiable
Portable

An alternative exists for very low volumes. The MyGuichet.lu portal lets you create and send compliant electronic invoices manually, without a dedicated access point. It is a viable solution if you issue a few public-sector invoices a year. Beyond that, manual entry becomes more expensive than automation.

Question 03

How to issue your first Peppol invoice, step by step.

Five steps, generally two working days when the software already includes an access point. Check your scope, choose the access point, register the Peppol identifier, activate the BIS Billing 3.0 format, then test before the first live invoice. The step most often neglected is the last one: a technical rejection of a live invoice delays your payment by as long as the correction takes.

Step 01

Check whether you are really affected

The trigger is the nature of the customer and the contractual framework: a Luxembourg public sector body, under a public contract or a concession. If you only invoice private customers, the obligation does not apply yet. This check takes five minutes and avoids a pointless investment.

Scope clarified

Step 02

Choose your access point

Three possible routes. Your software includes an access point natively, as Odoo does from version 17: you only need to activate it. Your software does not include one and you add a third-party provider, with a monthly subscription typically between €20 and €200 depending on volume. Or your volume is very low and MyGuichet.lu is enough.

Channel chosen

Step 03

Register your Peppol identifier

Your access point registers your company in the network directory, usually on the basis of your Luxembourg VAT number. This registration makes you reachable and also lets you receive Peppol invoices from your suppliers, something many companies only discover after the fact.

Identifier active

Step 04

Activate the format and complete the data

The BIS Billing 3.0 format requires fields that your PDF invoices may not have carried: order reference, recipient identifier, standardised tax codes. This is the most frequent source of rejection. FSL checks these fields on your customer records before the first issue.

Compliant data

Step 05

Test, then issue live

A test invoice is sent to the relevant public recipient, and the network's acknowledgement of receipt is checked. Only then does the first live invoice go out. The issued XML and the acknowledgement are archived with the accounting entry, which forms the audit trail required in the event of an inspection.

First invoice issued

QUESTION 04

What does the ViDA directive change on 1 July 2030?

Directive (EU) 2025/516, known as ViDA, adopted by the Council on 11 March 2025, provides that from 1 July 2030 intra-Community transactions between businesses give rise to a structured electronic invoice compliant with the EN 16931 standard, together with near real-time data transmission to the tax authorities. The PDF then ceases to be recognised as an electronic invoice for these transactions. The harmonisation of national regimes is planned for January 2035. These deadlines can still move, so check the law in force before any major decision.

April 2025Member States may impose domestic
B2B without authorisation

July 2030Structured invoice mandatory
for intra-Community B2B

July 2030Near real-time digital reporting,
end of DEB returns

January 2035Harmonisation of existing
national regimes

What your neighbours are doing

The shift is already under way

BelgiumB2B mandatory since January 2026
Germanyreceipt mandatory since January 2025
Francestarting September 2026
LuxembourgB2G done, B2B not yet imposed

The concrete risk

Your foreign customers, ahead of the law

A Belgian customer can require Peppolstarting today
So can a German principalreceipt mandatory
Refusing costs you the contractnot a fine
The constraint comes from the marketbefore the legislator

What it costs to anticipate

Two hours today

Activation on Odoonative, no extra licence
Identifier registrationdone by the access point
Customer record checkmandatory fields
Testing and go-live2 h at the Starter rate

What it costs to be forced

A migration under pressure

Emergency tool changeat the worst moment
Unplanned data migrationcost multiplied
Training during the closing periodoverloaded team
Risk of rejection on live invoicescash flow

Our plans

What does Odoo cost with an accounting firm included?

Four plans, from the free trial with no credit card to a group integration on quotation. Configuration is billed once, at a fixed fee. Accounting firm support is monthly, from €149 excl. VAT. No commission on Odoo licences: they are re-invoiced to you at the publisher's price, to the euro.

No credit card 01 · Entrepreneur

Try Odoo for 15 days, with a licensed accountant connected to your database.

0 EURFree trial, no commitment, cancel in one click

then €149 excl. VAT / month Monthly accounting firm support, if you continue

Freelancer, business founder, very small business still invoicing in Word or Excel.

Odoo database opened the same day
Luxembourg chart of accounts PCN 2020 pre-loaded
VAT 17 / 14 / 8 / 3% already configured
Licensed accountant added in a supervisory role, at no charge during the trial
30-minute kick-off video call included
Your data remains your property

Start for free

Immediate opening. No card required.

02 · Starter

You already have Odoo. We unblock what is stuck.

150 EURexcl. VAT / hour, minimum block of 2 hours, pay as you go

then €249 excl. VAT / month Accounting firm support, optional

Small business or SME already on Odoo, stuck on a specific point: VAT, Peppol, banking, analytics.

Targeted sessions, you set the pace
VAT configuration and eCDF filing
Peppol invoicing activation
PSD2 bank connection (BIL, BCEE, BGL, ING)
Analytical plan and cost centres
Written report after each session

Book 2 hours

Slot within 5 working days.

Most requested 03 · Business

Odoo up and running in 10 working days. Fixed price.

3,900 EURexcl. VAT, fixed fee. Any overrun is at our cost

then €590 excl. VAT / month Bookkeeping, VAT and annual accounts included

SME with 5 to 30 employees that wants to stop juggling an accounting package, a CRM and a spreadsheet.

Full LuxGAAP configuration
Migration of 12 months of history
Trial balance, general ledger, partners, fixed assets
Automatic bank connection
4-hour team training, on site or by video call
Go-live within 10 working days for a simple file
VAT returns and annual accounts included

Get my quote within 48 h

3-month commitment. No automatic renewal.

04 · Corporate

Groups, SOPARFIs, multi-entity setups and manufacturing.

from 12,000 EURexcl. VAT, custom quote after a scoping review

then from €1,500 excl. VAT / month Accounting firm, consolidation and reporting

Multi-company group, SOPARFI, family office, manufacturer with production or batch traceability.

Multi-company and multi-currency at ECB rates
LuxGAAP consolidation, automatic eliminations
MRP production, bills of materials, quality
REST API and connection to existing tools
Quarterly investor reporting
Single point of contact, directly reachable

Request a scoping call

Reply within 24 h. Scoping included.

Your integrator Your own or one of our partners,
who configures and maintains the instance

FSL Licensed accountant, in the same database,
VAT, eCDF, FAIA and annual accounts

One single environment for the software and the accounting,
with no three-way coordination

Odoo licences re-invoiced to the euro. FSL takes no publisher commission. Odoo pricing depends on the plan chosen, the number of users and the hosting mode, with Odoo.sh carrying separate costs. They are invoiced directly by Odoo or re-invoiced at the applicable publisher rate, to the euro. You remain the owner of your instance and can leave at any time: we hand over all access within 30 days, with no exit fees.

Question 06

Peppol invoicing FAQ for Luxembourg

Eight questions marked up with FAQPage Schema.org. Legal references point to the Luxembourg and European texts in force, which may change.

Is Peppol invoicing mandatory in Luxembourg?+

Peppol invoicing is mandatory in Luxembourg for any invoice addressed to the public sector: the law of 13 December 2021, which transposes Directive 2014/55/EU, requires economic operators to use a structured electronic invoice under a public contract. The law of 13 December 2021, which amends the law of 16 May 2019 and transposes Directive 2014/55/EU, requires economic operators to issue structured electronic invoices when they invoice a Luxembourg public sector body. The rollout was staggered from 18 May 2022 to 18 March 2023, the date from which all companies are covered. For private B2B, the obligation is not yet general in Luxembourg.

What exactly is the Peppol network?+

The Peppol network is a European network for exchanging structured business documents, run by the OpenPeppol association, that works through certified access points exchanging invoices with one another. The Grand-Ducal Regulation of 13 December 2021 designated it as the common delivery network of the Luxembourg public sector. The Grand-Ducal Regulation of 13 December 2021 designated it as the common delivery network for the automated receipt of invoices by the Luxembourg public sector. It works through certified access points that exchange documents with one another.

Is a PDF sent by email an electronic invoice?+

A PDF sent by email is not an electronic invoice within the meaning of the regulations: it is an image that the recipient has to read or re-enter, whereas Directive 2014/55/EU requires a structured file that can be processed automatically, in practice an XML in the Peppol BIS Billing 3.0 format. A PDF is an image that the recipient has to read or re-enter. An electronic invoice within the meaning of Directive 2014/55/EU is a structured file, in practice an XML in the Peppol BIS Billing 3.0 format, that can be processed automatically. This distinction becomes central with ViDA: from 1 July 2030, a PDF will no longer be recognised as an electronic invoice for intra-Community transactions.

Which Peppol invoice format should be used in Luxembourg?+

The Peppol invoice format to use in Luxembourg is Peppol BIS Billing 3.0, based on the UBL 2.1 syntax and aligned with the European standard EN 16931. It is the same format as in Belgium, France, Italy and Spain. It is the same format used in Belgium, France, Italy and Spain: a single implementation covers all your European customers, which is Peppol's main advantage over a proprietary solution.

What happens in 2030 with the ViDA directive?+

In 2030, the ViDA directive makes the structured electronic invoice mandatory for intra-Community transactions between businesses: from 1 July 2030, these transactions give rise to an invoice compliant with the EN 16931 standard and to near real-time data transmission to the tax authorities. The harmonisation of national regimes is planned for January 2035. These deadlines may change.

Do I need to change software to issue Peppol invoices?+

Changing software to issue Peppol invoices is not always necessary: there are three routes depending on your current tool, activating an access point that is already built in, adding a third-party provider, or manual entry on MyGuichet.lu for very low volumes. Three routes: your software already includes an access point and you only need to activate it; you add a third-party provider for a monthly subscription; or your volume is very low and MyGuichet.lu is enough. FSL always starts by checking what your current tool can already do before proposing a change.

How much does Peppol setup cost?+

Peppol setup costs about €300 excl. VAT at FSL, i.e. two hours at the Starter rate covering activation, identifier registration and test invoices. On Odoo, sending and receiving through Peppol are native and require no additional licence. At FSL, activation, identifier registration and testing generally take two hours, i.e. €300 excl. VAT at the Starter rate, and are included at no extra charge in the Business and Corporate packs. A third-party access point provider for other software typically costs between €20 and €200 per month depending on volume.

Are my Peppol invoices archived automatically?+

Your Peppol invoices are not archived automatically by the network: Peppol carries the documents, it does not retain them. The ten-year retention obligation in Luxembourg remains entirely your responsibility. The ten-year retention obligation remains your responsibility. On an Odoo database configured by FSL, the issued XML and the network acknowledgement of receipt are kept with the corresponding accounting entry, which rebuilds the reliable audit trail required in the event of an inspection.

Odoo hub

Go further with Odoo in Luxembourg

The Odoo pages of Financial Services Luxembourg, licensed accountant: integration, configuration, VAT, migration and e-invoicing.

Let us check together whether you are compliant.

Thirty minutes by video call to establish whether the obligation applies to you, what your current software can already do, and what is left to activate. Free diagnostic, no commitment. If your tool is enough, we will tell you.

Request my Peppol diagnostic +352 661 198 544

✓

Free diagnosticThirty minutes, no commitment

✓

Native on Odoo 17 and 18No additional licence

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Activation in 2 hoursIncluded in the Business packs

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Test before live issueZero rejections on your real invoices

Peppol invoicing in Luxembourg: who is affected, and how to get set up in 48 hours.