02.04.2025: Invoice and itemized bill

Art. 20 para. 3 of the Ordinance of January 14, 2025 on electronic communications networks and services (VKND), Law. Gaz. 2025 No. 52, reads as follows:

3) If the invoice or itemized bill is provided in electronic form, the subscriber must be able to receive both in paper form upon separate request and for a reasonable fee. If the contractual relationship does not enable the sending of invoices or itemized bills in electronic form, the transmission of the invoice or itemized bill must be provided free of charge in paper form.

This provision means that, apart from the exceptions mentioned, the provider is free to charge their subscribers a reasonable fee for sending the invoice and itemized bill by post if the invoice or itemized bill is generally made available in electronic form.

If electronic delivery has not yet been agreed with the subscriber as standard, the provider can stipulate electronic transmission as standard in its general terms and conditions, for example. Existing subscribers can be switched to the new standard in compliance with the relevant provisions (information, lead times, right of objection or termination).

For all subscriber relationships that allow for sending or providing access to invoices or itemized bills in electronic form, reasonable fees can be charged if the subscriber requests to receive them in written form by post. These include, in any case, all contractual relationships that include an internet access service (whether via a fixed or mobile network). In addition, the AK considers it appropriate and justified to offer the corresponding invoice in electronic form only, free of charge, as standard for all contracts for IT services, such as security services, housing or hosting.

For services that do not allow for electronic transmission of the invoice (and the itemized bill) or retrieval/receipt, however, no fee may be charged for the paper invoice. This applies to subscriber relationships that exclusively include TV and/or a landline connection, but no internet access.

Since the relevant provisions are based on the “electronic provision”, the AK considers it also permissible for invoices or itemized bills to be made available free of charge via a customer portal. In all cases of electronic provision, it must be taken into account that, according to paragraph 4 of the above-mentioned provision, the provider must keep the invoice in a storage and reading-capable format for a period of seven years free of charge.

All legal bases are linked under the heading “Legal bases” on the AK website and can be accessed at www.gesetze.li (only in German). If you have any questions, please do not hesitate to contact us.

Last updated: April 2025