Peppol ID in Luxembourg: get yours before 1 January 2028
Laurent Tousch7 min readFREN

Learn more about AI implementation in Luxembourg, and follow the bill itself on our e-invoicing 2028 tracker, which we update whenever it moves in Parliament.
Most Luxembourg finance teams have heard that "e-invoicing is coming in 2028". Far fewer have asked the practical question that comes first: what is our address on the network, and does anyone else know it? An e-invoice cannot reach you without a Peppol ID, and you cannot send one to a customer whose ID you do not have. That is a master-data problem before it is a software problem.
I work on invoice and supplier-data automation at 20 More, and the pattern I see is consistent: companies choose the software first and discover the data gap later. This guide is the order I would do it in.
What does bill 8815 change, and when?
Luxembourg already requires e-invoices for sales to the public sector. Under the Law of 16 May 2019, phased in between 18 May 2022 and 18 March 2023, every supplier to a Luxembourg public body must send a structured e-invoice, through Peppol or MyGuichet.lu (Guichet.lu).
Bill n° 8815, filed at the Chambre des Députés on 30 July 2026 (dossier 8815), extends that to invoices between businesses established in Luxembourg. It transposes part of the EU's VAT in the Digital Age package, Council Directive (EU) 2025/516 (EUR-Lex). As drafted:
| Obligation | Who | From |
|---|---|---|
| Be able to receive structured e-invoices | All in-scope businesses | 1 January 2028 |
| Issue structured e-invoices | Larger businesses | 1 July 2028 |
| Issue structured e-invoices | All other in-scope businesses | 1 January 2029 |
"Larger" here means, under bill 8815, exceeding two of three thresholds on 2026 figures: a balance sheet of €7.5 million, net turnover of €15 million, or 50 employees. A PDF sent by email will no longer count as an e-invoice: the invoice must follow the European standard EN 16931 in a structured format.
The bill is still before Parliament (the Finance Committee has it), so the dates can move. Two things will not: the receiving date comes first and applies regardless of size, and the network is Peppol, which Luxembourg already uses for the public sector.
What is a peppol ID, exactly?
Peppol is a network of certified access points that exchange e-invoices in a common format. Every participant has an identifier made of a scheme and a value. For Luxembourg organisations the scheme is 9938, and the value is either:
- your VAT number, written in lower case:
9938:lu10061242, or - your 11-digit national company number (the matricule):
9938:12345678910.
Both formats are documented by the Luxembourg e-invoicing portal (efacturation.public.lu). The Luxembourg Peppol Authority, which oversees the network nationally, is the Ministry for Digitalisation.
Two practical consequences follow. First, pick one identifier and use it consistently: a customer's system looking for 9938:lu… will not find you registered under your matricule. Second, your VAT number is already public, so your customers can guess your Peppol ID, but they cannot know whether it is actually registered on the network until they check.
How do you get a peppol ID in Luxembourg?
There is no form to fill in at a ministry. You become a Peppol participant by connecting through a certified Peppol service provider (an access point), which registers your identifier on the network and receives invoices on your behalf. The official list of certified providers is published by OpenPeppol (peppol.org).
In practice there are three routes:
- Through your accounting or ERP software. Most packages used in Luxembourg either include a Peppol connection or partner with a provider. This is the cleanest route: invoices arrive where they will be booked.
- Through a standalone provider, which receives invoices and forwards them to you or into your system. Useful when your software has no connector yet.
- MyGuichet.lu, the State's free portal, which works for sending invoices to the public sector through web forms. The government describes it as suited to businesses that issue few invoices. It is manual, so it does not scale to receiving hundreds of supplier invoices a month.
Whichever you choose, ask the provider three questions: which identifier they will register (VAT number or matricule), whether they will publish you in the Peppol Directory, and how received invoices reach your accounting system without re-keying.
How do you check whether a customer or supplier is on peppol?
This is where most teams go wrong. There are two public tools, and they are not the same:
- The Peppol Directory lets you search participants by name or identifier. Listing there is optional, so a company missing from the Directory may still be on the network.
- The Peppol lookup service checks whether a specific identifier is registered and which document types it can receive (peppol.org). This is the check that matters before you send.
So the reliable method is: build the identifier from the VAT number you hold (9938:lu + the eight digits), then look it up. If it does not resolve, ask the customer for the identifier their provider registered; do not assume.
A readiness plan for a 20–200 person company
Here is the sequence I would run between now and the end of 2027. It is deliberately boring, because the failure mode in e-invoicing projects is almost never the technology.
By the end of 2026
- Decide whether you are in the July 2028 or January 2029 issuing group, using your 2026 accounts against the three thresholds above.
- Ask your accounting or ERP vendor, in writing, how and by when they will send and receive Peppol invoices.
First half of 2027
- Choose your provider and your identifier (VAT number or matricule). Register.
- Clean the master data: every supplier and customer record needs a valid VAT number, a checked IBAN and, eventually, a Peppol ID. Our companion guide covers this in detail: supplier master data before e-invoicing.
Second half of 2027
- Run a pilot: receive a few real e-invoices end to end, into the ledger, with approval and payment.
- Tell your suppliers your Peppol ID. Put it on your invoices, your order confirmations and your supplier onboarding form.
From 1 January 2028 (bill 8815 as drafted)
- Receive everything that arrives through Peppol. Keep a simple exception queue for invoices that fail validation, because some will.
Where automation earns its money is not the network connection. It is what happens after an invoice arrives: matching it to the purchase order, checking the VAT rate, routing approvals and posting it. That is the work behind our invoice intake use case for Odoo, Sage BOB50 and Business Central, and the projects we price openly.
Frequently asked questions
Is e-invoicing mandatory in Luxembourg today?
For invoices to the public sector, yes: since 18 March 2023 every supplier to a Luxembourg public body must send structured e-invoices. For invoices between businesses, not yet: bill 8815 would require all in-scope businesses to be able to receive them from 1 January 2028, but Parliament has not voted it.
What is the peppol ID format in Luxembourg?
Luxembourg uses the scheme 9938. The identifier is 9938 followed by a colon and either your VAT number in lower case (for example 9938:lu12345678) or your 11-digit national company number. Use one consistently and make sure it is the one your provider registered.
Do small businesses need a peppol ID in 2028?
As bill 8815 is drafted, yes, to receive invoices: every in-scope business must be able to receive structured e-invoices from 1 January 2028. Businesses below the size thresholds would only have to issue them from 1 January 2029.
Is being in the peppol directory the same as being on peppol?
No. Listing in the Peppol Directory is optional, so a company can be on the network without appearing there. To confirm that an identifier can receive invoices, use the Peppol lookup service, not the Directory.
If you want help with the data side or the automation after the connection, send us a short description of your set-up and we will tell you where the work is.
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