Last updated 2025-08-22
Quick overview
Luxembourg already enforces gender-based reporting obligations through its Labor Code. Employers with at least 15 employees must share gender-disaggregated workforce statistics with internal employee representatives. While there is no requirement for a public gender pay gap report, employers are expected to comply with equal pay principles and provide information to staff delegations and equality officers.
Luxembourg has not yet published draft legislation to transpose the EU Pay Transparency Directive (EUPTD). The Directive must be implemented by June 7, 2026, and is expected to significantly expand employer obligations, including salary range transparency, bans on salary history questions, and new pay reporting duties.
Reporting requirements
Which companies must report?
All public and private sector employers in Luxembourg with 15 or more employees must hold elections to appoint a staff delegation. Employers are required to provide gender-based workforce statistics to this staff delegation and to the designated equality officer.
What information needs to be reported?
Employers must provide the following gender-based statistics to the staff delegation and equal opportunities officer twice per year:
Recruitment
Promotions
Transfers
Dismissals
Remuneration
Training
When and where to send the data?
The data must be disclosed internally every six months. There is no requirement to submit information to a central regulator or government body.
Who can see the results?
The statistics are shared only with the staff delegation and the designated equal opportunities officer. There is no obligation to publish the information externally.
Equal pay laws
Luxembourg’s Labour Code requires employers to ensure men and women receive equal pay for equal work or work of equal value. Authorities responsible for enforcing these rights include the Labour and Mines Inspectorate and the Employment Development Agency.
Employers who fail to comply can be fined between EUR 251 and EUR 25,000, with penalties increasing to EUR 50,000 for repeat offenses within two years.
Employee rights
Employees have the right to equal pay and treatment. Through their staff delegation and equality officer, they are entitled to receive gender-based statistics twice a year. Equality officers have the right to consult, provide opinions on the data, and propose internal training on equal opportunities.
Currently, there is no statutory right for employees to request individual pay data or average pay levels by gender. However, such rights are expected to be introduced under EU rules.
Risks of non-compliance
Employers who fail to provide gender-disaggregated data to the staff delegation can face fines between EUR 251 and EUR 15,000. Repeat offenses can lead to doubled fines. Obstructing the staff delegation or equality officer’s duties is also punishable under the Labour Code. Enforcement is overseen by the Labour and Mines Inspectorate and, if necessary, the Labour Court.
What will change by 2026
New EU-wide rules
Under the EU Pay Transparency Directive, which must be transposed into Luxembourg law by June 7, 2026, employers will face several new obligations:
Salary range disclosures in job postings or prior to interviews
Prohibition on requesting candidates’ salary history
Employee rights to request pay information, including average pay levels broken down by gender for roles of equal value
Regular gender pay gap reporting, with scope depending on employer size
Joint pay assessments if unjustified gaps of 5 percent or more are identified and persist
How Luxemburg is likely to apply them
As of mid-2025, Luxembourg has not yet published draft legislation to implement the Directive. Based on existing practice, new rules will build on current obligations by adding transparency rights for employees, formal reporting duties by employer size, and stronger enforcement mechanisms. Employers should expect stricter requirements around disclosure of pay structures and the potential prohibition of confidentiality clauses relating to pay.
FAQ
Do Luxembourg employers need to publish gender pay gap reports today?
No. Employers only need to share gender-disaggregated workforce statistics internally with their staff delegation and equality officer twice per year.
Who enforces equal pay in Luxembourg?
The Labour and Mines Inspectorate and the Employment Development Agency are responsible for enforcement.
What are the penalties for non-compliance?
Fines range from EUR 251 to EUR 25,000, with repeat offenses reaching EUR 50,000.
When will the EU Pay Transparency Directive apply in Luxembourg?
By June 7, 2026, Luxembourg must have fully transposed the Directive into national law.
Helpful resources
Luxembourg Labour Code
Labour and Mines Inspectorate (Inspection du travail et des mines)
Employment Development Agency (ADEM)
European Commission – Pay Transparency Directive overview
