By two laws published on 19 December 2025, the Luxembourg regulator significantly reshaped the legal framework applicable to companies operating in the retail and craft sectors.
The first law introduces a new regime governing opening hours in the retail and craft sectors (the “Opening Hours Law”). It will enter into force on 19 June 2026, i.e. six months after its publication, and repeals the long-standing Law of 19 June 1995 governing the closure of retail shops.
The second law amends Article L. 231-4 of the Labour Code and revises the rules governing Sunday work in the retail and craft sectors (the “Sunday Work Law”). This law entered into force on 1 January 2026.
Taken together, the Opening Hours Law and the Sunday Work Law significantly modernise the organisation of retail and craft activities in Luxembourg. While they offer increased operational flexibility, they also introduce new coordination requirements between commercial opening policies and labour law compliance, which employers must carefully anticipate.
New rules on opening hours
A clarified scope of application
The Opening Hours Law applies to all commercial and craft activities subject to a business licence under the amended Law of 2 September 2011, provided that such activities involve direct sales or services to end consumers carried out in a physical point of sale accessible to the public.
The notion of “physical point of sale” refers to any retail establishment with a genuine sales activity operated from a sales area.
Several activities are expressly excluded from the scope of the Opening Hours Law, including in particular:
- cinemas and shops directly linked to cinema operations;
- points of sale in railway stations and airports;
- restaurants, cafés, bars and accommodation services;
- fairs, markets, temporary street sales and braderies;
- certain family businesses operating exclusively with non-salaried family members outside the statutory opening hours;
- fitness centres, swimming pools, indoor and outdoor playgrounds;
- funeral services;
- certain motorway service stations;
- sales through vending machines.
New statutory opening hours
As a general rule, opening hours are now set as follows:
- Monday to Friday: 5:00 a.m. to 9:00 p.m.;
- Saturdays, Sundays, public holidays and the day before public holidays: 5:00 a.m. to 7:00 p.m.;
- 22 June, 24 December and 31 December: 5:00 a.m. to 6:00 p.m.
Outside these time slots, customer access and direct sales to customers are strictly prohibited.
Mandatory closure on certain public holidays
All establishments falling within the scope of the Opening Hours Law must remain closed on 1 January, 1 May and 25 December.
An exception applies to butchers, bakeries, pastry shops, caterers and consumption rooms, which may remain open on those days from 5:00 a.m. to 7:00 p.m.
Other establishments may also open on these dates within the same time range only if this is expressly provided for under a collective bargaining agreement (CBA) or an inter-professional agreement.
Extended and continuous opening: flexibility subject to agreement
Notwithstanding the opening hours indicated above, the Opening Hours Law introduces increased flexibility, subject to collective arrangements:
- Opening hours may be extended until 1:00 a.m. on the basis of a CBA or inter-professional agreement.
- For certain “essential” activities (e.g. food, medicines and health products, hygiene products, books and newspapers, pet food, fuel, telecommunications equipment, etc.), 24/7 continuous opening from Monday to Sunday may be authorised under a CBA or inter-professional agreement.
- Independently of the above, all establishments may benefit from a 24-hour continuous opening up to twice per calendar year, provided that the employer notifies the Minister for the Middle Classes via a secure electronic portal at least one week in advance.
Sanctions for non-compliance
Any breach of the provisions relating to opening hours or closures may result in an administrative fine ranging from EUR 1,000 to EUR 25,000. In the event of a repeat offence within five years, the authorities may additionally order the temporary closure of the establishment for a period of six months to two years.
Extended possibilities for Sunday work
As from 1 January 2026, employees in retail and craft businesses within the meaning of the Opening Hours Law may be employed on Sundays for up to eight hours (compared to a maximum of four hours before), subject to conditions linked to the size of the workforce:
- Companies with fewer than 30 employees may employ staff for up to eight hours on Sundays without additional formalities.
- Companies with 30 employees or more may employ staff for up to four hours on Sundays by default. The duration may be increased to eight hours only under a collective bargaining agreement or an inter-professional social dialogue agreement.
In the absence of such an agreement, companies employing 30 or more employees may request authorisation from the Minister for Labour to employ staff for up to eight hours on a maximum of six Sundays per calendar year, where such Sundays constitute usual opening days in the retail sector.
The statutory wage increase for Sunday work remains fully applicable.
Implications for employers
The two Laws form a coherent but legally distinct framework:
- the Opening Hours Law determines when establishments may be open to the public;
- the Sunday Work Law determines how long employees may actually work, particularly on Sundays.
Accordingly, lawful opening does not automatically imply lawful working time!
Employers are strongly encouraged to:
- carry out a comprehensive review of their opening policies and staffing arrangements in light of the new rules;
- verify whether their existing collective bargaining agreements or social dialogue arrangements allow for extended opening hours and/or extended Sunday work;
- anticipate, where necessary, the negotiation or amendment of collective or inter-professional agreements in order to lawfully implement the new rules.
Our Employment, Compensation and Benefits department remains at your entire disposal to support you in assessing the combined impact of the Opening Hours Law and the Sunday Work Law, and in ensuring full compliance with both the commercial and labour law aspects of these reforms.
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