What is the maximum EAA fine in Luxembourg?

The maximum penalty is €1,000,000. Three-tier structure, confirmed from the official text (Art.

Who enforces the European Accessibility Act in Luxembourg?

Office de la surveillance de l'accessibilité des produits et services (OSAPS) — a dedicated government administration under the Minister responsible for disability policy. OSAPS holds sole sanctioning power (Art. 3, 32-33) and collaborates with ILNAS on the national market-surveillance programme and with Customs and the Police grand-ducale for investigatory support — no separate sector regulators (e.g. for telecoms or banking) share its sanctioning authority. Details are published at https://accessibilite-produits-services.public.lu/fr/osaps.html.

Since when does the EAA apply in Luxembourg?

The requirements apply from 28 June 2025, the EU-wide date, transposed into Luxembourg by Luxembourg's national implementing law.

Are small businesses exempt from the EAA in Luxembourg?

Only microenterprises — fewer than 10 staff and annual turnover or balance sheet total of €2 million or less — and only for services. A microenterprise in Luxembourg that places a covered product on the market still has to make that product accessible.

How do I report an inaccessible website in Luxembourg?

Complaints go to the national complaint route at https://guichet.public.lu/fr/citoyens/citoyennete/accessibilite/accessibilite-produits-services/declaration-non-conformite-accessibilite-pp.html. The enforcement authority above handles market surveillance separately.

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European Accessibility Act: Luxembourg

Last verified 2026-09-29.

Applies from: 2025-06-28
Maximum penalty: €1,000,000
Enforcement authority: Office de la surveillance de l'accessibilité des produits et services (OSAPS) — a dedicated government administration under the Minister responsible for disability policy. OSAPS holds sole sanctioning power (Art. 3, 32-33) and collaborates with ILNAS on the national market-surveillance programme and with Customs and the Police grand-ducale for investigatory support — no separate sector regulators (e.g. for telecoms or banking) share its sanctioning authority. — https://accessibilite-produits-services.public.lu/fr/osaps.html
Microenterprise exemption: Yes — under the EAA's EU-wide microenterprise exemption for services

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National law: Loi du 8 mars 2023 relative aux exigences en matière d'accessibilité applicables aux produits et services
File a complaint: https://guichet.public.lu/fr/citoyens/citoyennete/accessibilite/accessibilite-produits-services/declaration-non-conformite-accessibilite-pp.html
Notes: Three-tier structure, confirmed from the official text (Art. 32-33). Administrative fines of €250-15,000, imposed directly by OSAPS, cover procedural violations only (refusing documents, obstructing surveillance, ignoring OSAPS decisions). Criminal fines of €251-500,000, imposed by a court, cover substantive non-compliance with the accessibility requirements themselves, scaled to severity, units affected, and people affected. A repeat offence (prior EU convictions count toward recidivism) raises the criminal band to €500-1,000,000, which is reported as the maximum here. Courts may additionally order confiscation or destruction of goods and confiscation of illicit profits.

Who is obligated in Luxembourg

Luxembourg's Law of 8 March 2023 transposes the EAA's scope essentially verbatim: Article 1 lists the same product categories (general-purpose computer hardware and operating systems, self-service terminals — payment terminals, ATMs, ticketing/check-in machines, interactive information terminals — plus consumer terminal equipment for electronic communications and audiovisual media access, and e-readers) and the same service categories (electronic communications, audiovisual media access, air/rail/bus/waterborne passenger transport information and booking elements, consumer banking, e-books, e-commerce), plus emergency-communications access to 112. Manufacturers, importers, distributors, and service providers each carry distinct documented obligations — technical files kept five years, CE marking and EU declarations of conformity for products; public accessibility explanations for services — and must cooperate with OSAPS, Customs, and Police on request. The standard EU microenterprise exemption (fewer than 10 staff, turnover or balance sheet under €2,000,000) applies only to service providers (Art. 6§4) — microenterprises handling products still owe full compliance, though they're excused from documenting their disproportionate-burden assessments unless OSAPS specifically asks.

What happens if you don't comply

OSAPS is both regulator and prosecutor-referrer: it runs market surveillance directly, and economic operators must self-report known non-conformities the moment they discover them, keeping a log of non-compliant units and complaints received. Two separate tracks follow. Procedural failures — refusing to hand over documents, obstructing an inspection, or ignoring an OSAPS compliance order — draw an administrative fine of €250 to €15,000, decided in writing by OSAPS itself, payable within 30 days, appealable to the Tribunal administratif within three months. Substantive non-compliance with the actual accessibility requirements is instead a criminal matter: a court-imposed fine of €251 to €500,000, scaled to severity, units affected, and people affected, rising to €500-1,000,000 for a repeat offence — with prior convictions anywhere else in the EU counting toward recidivism. Courts may also order confiscation or destruction of the offending goods and confiscation of illicit profits. In practice OSAPS's own enforcement toolkit is modest; real financial exposure comes from referral to the criminal courts.

How this differs from the EU baseline

Luxembourg's most distinctive choice is routing substantive accessibility breaches through the criminal courts rather than a purely administrative fining regime — OSAPS can only fine directly for procedural obstruction (up to €15,000); the headline €500,000/€1,000,000 figures are criminal penalties a judge imposes, not an administrative sanction OSAPS issues on its own authority. That's a heavier-weight mechanism than most EU states use, closer in spirit to Ireland's criminal track than to a typical regulator-fines-you model. Courts also have an explicit power to order confiscation and destruction of non-compliant goods and confiscation of illicit profits, which is unusually concrete. On the citizen side, Luxembourg created a single dedicated agency (OSAPS) purely for this directive, rather than folding enforcement into an existing consumer-protection or telecoms regulator as most neighbours did — and it built a specific MyGuichet.lu online reporting channel, open to anyone, not just the affected person, with no login required.

How to complain

Anyone — not only the person directly affected — can report a non-compliant product or service to OSAPS free of charge via the official MyGuichet.lu procedure for declaring a possible non-conformity with accessibility requirements, which can be filed with or without authentication (LuxTrust or eID). For website or digital-content accessibility issues specifically, OSAPS also runs a direct feedback channel by email, committing to a response within one month; unsatisfied complainants can escalate to Luxembourg's Service information et presse complaints form or to the Ombudsman. OSAPS can also be reached by phone or in person by appointment at its Luxembourg office.

Frequently asked questions about the EAA in Luxembourg

What is the maximum EAA fine in Luxembourg?: The maximum penalty is €1,000,000. Three-tier structure, confirmed from the official text (Art.
Who enforces the European Accessibility Act in Luxembourg?: Office de la surveillance de l'accessibilité des produits et services (OSAPS) — a dedicated government administration under the Minister responsible for disability policy. OSAPS holds sole sanctioning power (Art. 3, 32-33) and collaborates with ILNAS on the national market-surveillance programme and with Customs and the Police grand-ducale for investigatory support — no separate sector regulators (e.g. for telecoms or banking) share its sanctioning authority. Details are published at https://accessibilite-produits-services.public.lu/fr/osaps.html.
Since when does the EAA apply in Luxembourg?: The requirements apply from 28 June 2025, the EU-wide date, transposed into Luxembourg by Luxembourg's national implementing law.
Are small businesses exempt from the EAA in Luxembourg?: Only microenterprises — fewer than 10 staff and annual turnover or balance sheet total of €2 million or less — and only for services. A microenterprise in Luxembourg that places a covered product on the market still has to make that product accessible.
How do I report an inaccessible website in Luxembourg?: Complaints go to the national complaint route at https://guichet.public.lu/fr/citoyens/citoyennete/accessibilite/accessibilite-produits-services/declaration-non-conformite-accessibilite-pp.html. The enforcement authority above handles market surveillance separately.

Official source: https://legilux.public.lu/eli/etat/leg/loi/2023/03/08/a133/jo
Verified on 2026-09-29. This page is not legal advice — verify against the official source above before making compliance decisions.