Digital accessibility in Luxembourg: what the law requires of your website

Since 28 June 2025, digital accessibility has no longer been a matter for the Luxembourg public sector alone. Any private company above the micro-enterprise threshold that sells online, offers e-banking or operates in electronic communications must now comply, under the supervision of a dedicated authority. Here is what the law requires in practice, sector by sector.

Public sector: an obligation in force since 2019

The law of 28 May 2019 requires the websites and mobile applications of Luxembourg public sector bodies to be accessible, transposing European Directive 2016/2102 (source: legilux.public.lu). The law relies on a precise technical standard, EN 301 549, implemented locally through the RAWeb 1.1 framework, which sets the criteria a website or app must meet to be usable by a person with a disability. In practice, public bodies must publish an accessibility statement and notify the Service information et presse (the government's Information and Press Service) within 30 days of its publication or update, according to Luxembourg's official digital accessibility portal (source: accessibilite.public.lu).

Private sector: the turning point of 28 June 2025

The major change for businesses comes from the law of 8 March 2023, as amended, which transposes the European Accessibility Act (EU Directive 2019/882) into Luxembourg law (source: legilux.public.lu). This law has applied to businesses since 28 June 2025, according to the ministère de la Famille, de la Solidarité, du Vivre ensemble et de l'Accueil (Ministry of Family Affairs, Solidarity, Living Together and Reception) (source: mfsva.gouvernement.lu). Unlike the 2019 law, which covered only public administrations, this one directly targets private players whose activity involves certain digital services deemed essential.

Who is covered, who is exempt

The law provides an exemption for micro-enterprises: organisations with fewer than 10 employees whose annual turnover does not exceed 2,000,000 euros or whose annual balance sheet total does not exceed that same amount are exempt, according to the Office de la surveillance de l'accessibilité des produits et services (Office for the Surveillance of the Accessibility of Products and Services) (source: accessibilite-produits-services.public.lu). All other companies fall within scope as soon as they operate in one of the sectors concerned: e-commerce, e-banking, electronic communications, audiovisual media, passenger transport, the 112 emergency number, or the sale of certain products such as computers, smartphones, tablets, payment terminals and automated machines. A ten-employee SME that sells online, for example, is therefore potentially affected, even if accessibility has never appeared in its website specifications.

The checklist before a possible inspection

Before commissioning an audit, four questions will tell you where you stand:

• Is my company above the micro-enterprise threshold (10 employees, 2 million euros in turnover or balance sheet total) and does it operate in a sector concerned (e-commerce, e-banking, electronic communications...)?
• Have I published an accessibility statement for my website or application, as the regulations require for the public sector and, by extension of the same logic, as good practice for the private sector?
• Does my website meet the technical criteria of the EN 301 549 standard and the RAWeb 1.1 framework?
• Have I kept a record of my compliance steps, which would be useful in the event of a complaint or an inspection?

This checklist is not intended to replace an accessibility audit carried out by a professional, who alone can verify, criterion by criterion, whether your interfaces actually comply.

Penalties: what a non-compliant company risks

Enforcement of the law is the responsibility of the OSAPS, the Office de la surveillance de l'accessibilité des produits et services. According to the Luxembourg government, this authority receives reports of non-compliance and can order the withdrawal of a non-accessible product or service, or prohibit it from being placed on the market (source: mfsva.gouvernement.lu). The criminal penalties provided for by the law can reach 500,000 euros, rising to 1,000,000 euros for repeat offences. This level puts digital accessibility on the same footing as other digital compliance obligations already monitored in Luxembourg, such as the rules on cookies and consent enforced by the CNPD.

This article is for information purposes only and does not replace a technical accessibility audit or personalised legal advice. For companies that sell online, achieving compliance is often part of a broader digitalisation effort, alongside related obligations such as VAT on cross-border e-commerce.