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      With mandatory requirements expanding globally (please refer to our previous article), e-invoicing has firmly established itself as a priority for several companies. However, navigating the diverse landscape of e-invoicing models can be complex and requires a clear and structured roadmap. 

      Preparing the introduction of the ViDA package

      The introduction of the ViDA package – including the EU‑wide B2B cross-border e‑invoicing mandate, effective 1 July 2030, and the requirement to comply with the EN 16931 semantic model – requires companies to define a roadmap and address key technical and operational decisions. This is paramount for domestic companies trading with partners in other EU jurisdictions, and/or with strong B2B contexts, where invoice volumes and complexity are highest. 



      Understanding the technical framework supporting the e-billing 

      A solid understanding of the technical framework that supports the e-billing mechanism is essential to effectively address implementation challenges. This starts with understanding some key concepts and terminologies: 

      CIUS

      CIUS stands for ‘Common Interface for User Services’. It is a standardized framework or protocol that enables interoperability and consistent access to a set of user-facing services across different systems or platforms. CIUS typically defines common APIs

      CIUS defines the core data elements and rules that ensure consistent e‑invoice content. 

      Peppol

      Peppol (Pan‑European Public Procurement OnLine) is a secure, pan‑European e‑procurement network that enables standardized electronic exchange of business documents (such as invoices and orders) between organizations via certified access points, ensuring interoperability and simplified cross‑border transactions

      Peppol is the network Luxembourg uses for mandatory B2G e‑billing; it enables secure cross‑border exchange of structured documents (e‑invoices, orders, etc.). 

      Learn more
      Peppol BIS Billing 3.0

      Peppol in Luxembourg relies on Peppol BIS Billing 3.0, a CIUS profile implementing the European semantic model EN 16931‑1:2017 (XML UBL 2.1 or CII). 

      EN 16931

      EN 16931 is the European standard that defines the semantic data model for electronic invoicing (e‑invoicing) to ensure interoperability across public procurement and business-to-business transactions in the EU. It specifies a core set of required data elements, their meaning and structure, and supports exchange using different syntaxes (for example, UBL or UN/CEFACT). The standard aims to simplify cross-border invoicing, reduce processing costs and errors, and facilitate compliance with EU e‑invoicing mandates.

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      Schematron

      Schematron is an XML validation language used in e-invoicing to ensure compliance with business rules defined by standards like EN 16931 and Peppol BIS. It checks the meaning of XML documents, ensuring that they meet specific requirements, such as having a taxable amount and a correct VAT breakdown.

      CIUS

      CIUS stands for ‘Common Interface for User Services’. It is a standardized framework or protocol that enables interoperability and consistent access to a set of user-facing services across different systems or platforms. CIUS typically defines common APIs

      CIUS defines the core data elements and rules that ensure consistent e‑invoice content. 

      Peppol

      Peppol (Pan‑European Public Procurement OnLine) is a secure, pan‑European e‑procurement network that enables standardized electronic exchange of business documents (such as invoices and orders) between organizations via certified access points, ensuring interoperability and simplified cross‑border transactions

      Peppol is the network Luxembourg uses for mandatory B2G e‑billing; it enables secure cross‑border exchange of structured documents (e‑invoices, orders, etc.). 

      Learn more

      Peppol BIS Billing 3.0

      Peppol in Luxembourg relies on Peppol BIS Billing 3.0, a CIUS profile implementing the European semantic model EN 16931‑1:2017 (XML UBL 2.1 or CII). 

      EN 16931

      EN 16931 is the European standard that defines the semantic data model for electronic invoicing (e‑invoicing) to ensure interoperability across public procurement and business-to-business transactions in the EU. It specifies a core set of required data elements, their meaning and structure, and supports exchange using different syntaxes (for example, UBL or UN/CEFACT). The standard aims to simplify cross-border invoicing, reduce processing costs and errors, and facilitate compliance with EU e‑invoicing mandates.

      Learn more

      Schematron

      Schematron is an XML validation language used in e-invoicing to ensure compliance with business rules defined by standards like EN 16931 and Peppol BIS. It checks the meaning of XML documents, ensuring that they meet specific requirements, such as having a taxable amount and a correct VAT breakdown.


      Countries may apply national constraints (such as mandatory fields, code lists and identifier requirements) on top of CIUS to meet local legal and tax needs. For example, Luxembourg usually requires procurement references for public buyers. Under the ViDA framework, EN 16931 will become mandatory for cross border e invoicing from 1 July 2030, and member states are expected to converge toward extended Peppol-based B2B approaches.



      Exploring the key steps for successful implementation

      Proper guidance and structured support are essential in navigating a successful e-invoicing implementation process Here is a simplified roadmap: 

      1. Assess your needs and goals

      Begin by clearly defining your business needs and goals for e-invoicing. Consider the following factors:

      • Compliance requirements:

        Identify any mandatory e-invoicing regulations in your current and target operating markets.

      • Impact assessment:

        Map the upcoming regulatory requirements to your business footprint, entity profile and scenarios.

      • E-invoicing model:

        Identify e-invoicing models that align with your business requirements and the regulations in target markets

      • Process efficiency:

        Analyze your current invoicing processes and identify areas for improvement.

      • Integration with existing systems:

        Assess how e-invoicing will integrate into your existing ERP, accounting and other systems, considering both current and future state systems.

      • Data security and privacy:

        Ensure that your chosen e-invoicing solution is in compliance with the highest standards for data protection.

      2. Select a reliable e-invoicing provider

      Partner with a reputable e-invoicing provider that offers a comprehensive solution, including:

      • Compliance expertise:

        Strong understanding of e-invoicing regulations in your target markets.

      • Technology platform:

        A robust and scalable e-invoicing software provider to partner with.

      • Integration capabilities:

        Seamless integration with existing systems.

      • Customer support:

        Dedicated support throughout the implementation process.


      3. Plan and manage the implementation process

      Develop a detailed implementation plan that outlines the following:

      • Project timeline:

        Set realistic timelines for each phase of the implementation process (with a global roadmap for companies operating worldwide).

      • Governance framework:

        Implement a governance framework and high-level RACI to determine split of responsibilities across various internal (and external) teams.

      • Change management:

        Develop a comprehensive change management strategy to ensure user adoption and minimize disruption.

      • Testing and validation:

        Conduct thorough testing of the e‑invoicing solution before going live. Thoroughly map and test all jurisdictional validation rules (mandatory fields, code lists, identifier formats and automated business rules verification (Schematron)) using representative test cases and running pilots with real trading partners to confirm end‑to‑end acceptance, error handling and accounting reconciliation. 

      • Deployment:

        Deploy local processes and technology solutions to enable compliance by go-live date.

      4. Monitor and optimize

      Even after the go-live, e-invoicing should be managed as an ongoing compliance and performance program rather than a one‑off check. Organizations should implement automated dashboards and alerts to track key metrics (such as invoice acceptance/rejection rates, average processing time, transmission failures, reconciliation gaps and exception volumes), and schedule regular reviews to capture new or changed national CIUS/EN 16931 requirements. Proper analyses and root‑cause investigations should be done to prioritize fixes, update test cases and roll out incremental improvements; a release cadence for Schematron/validation updates and a clear change control process so regulatory updates do not disrupt operations should be maintained. Maintaining close collaboration with trading partners and service providers is also critical to ensure quick resolution of interoperability or data issues.


      How we can assist you 

      A successful e‑invoicing program combines operational resilience and continuous compliance. By following a structured roadmap – assess needs, choose the right provider, plan carefully, test comprehensively and monitor continuously – the risk of rejections, tax exposure and operational disruption is reduced, while realizing efficiency and cash flow benefits. Commitment to governance, training and proactive regulatory watch is key, so the invoicing processes remain compliant as rules evolve: when done right, e‑invoicing becomes a durable competitive advantage rather than merely a compliance obligation.

      We work hand in hand with you on tailored approaches covering all aspects of VAT, optimizing efficiency and compliance with a big-picture perspective.


      Our experts

      Jérôme Bernard

      Partner, Consulting, Public Sector and Healthcare Leader

      KPMG in Luxembourg

      Frederic Raepers

      Director, Indirect Tax

      KPMG in Luxembourg

      Quentin Warscotte

      Partner, Indirect tax

      KPMG in Luxembourg


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