European Accessibility Act Compliance in Luxembourg

The law applies to economic operators whose covered products are made available on the Luxembourg market or who provide covered services to consumers there. It covers e-commerce, consumer banking, e-books, electronic communications, access to audiovisual media services and parts of passenger transport, along with a defined list of consumer hardware and self-service terminals.

Article 1(1) lists the products: consumer general purpose computer hardware and its operating systems, payment terminals, the ATMs, ticketing machines, check-in machines and interactive information terminals intended to provide the services the law covers, consumer terminal equipment used for electronic communications or to access audiovisual media services, and e-readers. Article 1(2) lists the services: electronic communications, access to audiovisual media services, consumer banking, e-books and dedicated software, e-commerce, and the websites, mobile services, electronic tickets, travel information and self-service terminals of air, rail, inland waterway and bus passenger transport. Urban and suburban transport and regional transport are covered only for their interactive self-service terminals. Article 1(3) adds the answering of emergency communications to the single European emergency number 112 or to other national emergency numbers.

Article 1(5) leaves out archived content that is not updated or edited after 28 June 2025, and third-party content that the operator has not funded or developed and does not control. It also leaves out online maps and mapping services when the essential information for navigation is provided in an accessible digital form.

Article 6(4) exempts microenterprises that provide services from the service accessibility requirements and from every obligation tied to them. Article 2, point 14° defines a microentreprise (microenterprise) as an enterprise that employs fewer than ten persons and has an annual turnover or an annual balance sheet total of no more than EUR 2 million. The exemption covers services only. A microenterprise that deals in products still has to meet the product requirements, although Article 16(4) spares it from providing evidence for its assessment when it relies on the exceptions in Article 16(1).

Loi du 8 mars 2023 relative aux exigences en matière d'accessibilité applicables aux produits et services (Law of 8 March 2023 on accessibility requirements applicable to products and services), parliamentary bill No. 7975. The Chambre des Députés voted it on 9 February 2023 and the Conseil d'État waived the second vote on 28 February 2023. It was published in Mémorial A No. 133 of 15 March 2023 and entered into force on 28 June 2025 under Article 36. The Law of 29 August 2023, published in Mémorial A No. 579 of 18 September 2023, corrected an omission in Article 1(2)(3°) by adding the directive's exception for urban and suburban transport and regional transport, and it also entered into force on 28 June 2025. The consolidated text on Legilux lists it as the only amending act.

Transposition was late. Directive (EU) 2019/882 set a deadline of 28 June 2022, and the European Commission sent Luxembourg a letter of formal notice on 19 July 2022 in case INFR(2022)0312. It closed that case on 18 June 2025. Bill No. 8769, filed on 12 June 2026, would add rules on the training and examinations of OSAPS staff and replace Article 29 on the officials who record offences. On 26 September 2026 it was still in committee at the Chambre des Députés.

The law names no technical standard. Article 6(1) requires products and services to meet the accessibility requirements in Annex I of Directive (EU) 2019/882, as amended by the European Commission, and Article 35(1) applies later changes to that Annex from the day the amending EU act enters into force. Article 17(1) presumes conformity for products and services that meet harmonised standards whose references are published in the Official Journal of the European Union, and Article 17(2) does the same for technical specifications adopted by the Commission. No harmonised standard has been cited in the Official Journal under Directive (EU) 2019/882 so far, so the Article 17(1) presumption is not available yet.

OSAPS points businesses to EN 301 549 in its guidance. EN 301 549 V3.2.1 applies the WCAG 2.1 level AA success criteria to web content. EN 301 549 V4.1.1, which adopts WCAG 2.2 AA, was published on 2 September 2026 and is not yet cited in the Official Journal.

The Office de la surveillance de l'accessibilité des produits et services (OSAPS), created by Article 3(1) under the minister responsible for disability policy, supervises the products and services listed in Article 1(1) and (2) under Article 4(1), e-commerce included. The law names no separate sector regulator, and Article 4(1) has OSAPS work with the authorities that have specific responsibilities for the products and services concerned. For services, Article 28(2) gives the conformity checks to OSAPS and the Police grand-ducale, and OSAPS can prohibit or restrict a service that does not conform. For products, Article 28(1) adds the Administration des douanes et accises, and OSAPS can ban, restrict, withdraw or recall a product.

Under Article 15(4), a service provider whose service does not conform has to take corrective action and inform OSAPS immediately, and OSAPS accepts these declarations only through Guichet.lu or MyGuichet.lu. Under Article 16(7), an operator that relies on the exceptions in Article 16(1) for a specific product or service has to inform the supervising authority, which in Luxembourg is OSAPS, unless it is a microenterprise. Any natural or legal person may report a non-conforming service to OSAPS under Article 25(2), and a non-conforming product under Article 22(1). The Guichet.lu report is free, and OSAPS also takes reports through a form on its website, by telephone, WhatsApp, email or post.

Article 32(1) sets administrative fines of EUR 250 to EUR 15,000 for refusing requested information or obstructing market surveillance or service compliance checks, and Article 32(2) sets the same range for ignoring an OSAPS decision under Article 24(2) or Article 25(3). Under Article 32(3), those fines are payable within 30 days of notification of the written decision, even if an appeal is lodged.

Article 33(1) makes a breach of the accessibility requirements, or of the duties of manufacturers, importers, distributors and service providers, a criminal offence punishable by a fine of EUR 251 to EUR 500,000, set in proportion to the extent and seriousness of the non-conformity and to the number of units and people affected. It does not apply to microenterprises exempt under Article 6(4) or to cases covered by the Article 16(1) exceptions. Under Article 33(2) a repeat offender faces a fine of EUR 500 to EUR 1,000,000, and Article 33(3) also counts final convictions in another EU Member State for offences punishable under that state's transposition of the directive. OSAPS measures under Article 28(1) and (2) and its administrative fines can be appealed to the tribunal administratif within three months of notification under Articles 28(5) and 32(3).