Luxembourg accessibility law: Loi 28/05/2019 + EAA explained

Who has to comply

Public-sector since 2019; consumer services from 28 June 2025.

Luxembourg is a tiny but exceptionally wealthy market and a major financial-services hub, so many banking, payment and B2C financial platforms established there serve consumers across the EU. Under the EAA-implementing act extending the Loi du 28 mai 2019, a foreign store selling to Luxembourg consumers is covered on the country-of-consumption basis. The practical wrinkle is Luxembourg's trilingual context (French, German, Luxembourgish): accessibility statements are commonly published in French and German, and a single English statement is often treated as insufficient.

What the law actually requires

The technical baseline is WCAG 2.1 Level AA via EN 301 549. EN 301 549 references WCAG 2.1 Level AA in full and adds a few requirements specific to mobile apps and documents. Beyond the technical bar, Luxembourg requires the following operational items, which auditors check first because they are simple to verify:

• EN 301 549 / WCAG 2.1 AA

• Multi-language accessibility statement (FR/DE)

Penalties and how enforcement actually works

Administrative penalties per the EAA-implementing act.

Enforcement involves the Service Information et Presse (SIP) together with the Ministry for Digitalisation, which administered the 2019 public-sector regime and now extends to covered consumer services. Luxembourg's model is centralised and complaint-driven, with administrative penalties under the EAA-implementing act. Because the country's covered services skew heavily toward finance and cross-border platforms, enforcement attention tends to follow those higher-visibility operators, and the multilingual statement expectation is an early checkpoint.

Practical first steps for a Luxembourg site

If you are starting now and want to land before enforcement, run an automated audit, fix the high-impact issues (contrast, labels, keyboard, focus), publish an accessibility statement, and set up a feedback inbox. That sequence covers 80% of what auditors look for in a first sweep.

• Run a baseline scan to know your current score

• Fix critical and serious issues in priority order — these are the ones cited in complaints

• Publish a public accessibility statement on a stable URL (Luxembourg regulators expect this discoverable)

• Add a feedback channel and answer within the country-specified window

• Re-scan after every major release; track regressions