Luxembourg is taking a significant step toward a fully digital government and legal system with three new key legal instruments: the Law of 4 June 2025 on electronic signatures of acts in administrative matters, the Grand-Ducal Regulation of 4 July 2025 regulating the electronic communication of documents and notifications during bankruptcy and reorganisation proceedings, and the Draft law No. 8560 on electronic signatures for legislative and regulatory acts.
These legislative developments build on existing legislation, such as the amended law of 14 August 2000 relating to electronic commerce, which already allows for the use of electronic signatures for private agreements under certain conditions.
While these new instruments promote the use of qualified electronic signatures, they do not render traditional signatures obsolete. Electronic signatures remain optional, and handwritten signatures continue to carry full legal value in all applicable contexts.
This article provides an overview of these three new instruments and explains the different types of electronic signatures under the eIDAS Regulation (EU) No. 910/2014 on electronic identification and trust services.
Key Legal Instruments Supporting Luxembourg’s Digital Transition
Electronic signatures of acts in administrative matters: The Law of 4 June 2025
The Law of 4 June 2025 (formerly Draft law No. 8089) grants full legal value to electronic signatures and seals when used in administrative acts, whether issued by public authorities or by individuals interacting with the administration.
This reform allows for document to be signed or sealed electronically without requiring a handwritten signature or a physical copy, as long as the process complies with the requirements of the EU eIDAS Regulation (explained below).
The law establishes the equality of electronic and handwritten signatures for administrative purposes. However, it leaves open the possibility for signatories to continue using traditional, wet ink signatures if preferred.
Certain measures initially proposed, such as a central platform or a unique administrative identifier, were removed during the legislative process following critical opinions from the Council of State, the CNPD, and other institutional stakeholders, primarily due to concerns over data protection and legal clarity.
Electronic communication in insolvency and restructuring proceedings: Grand-ducal regulation of 4 July 2025
Further contributing to Luxembourg’s digital transition, the Grand-Ducal Regulation of 4 July 2025 establishes the legal framework for electronic communication of documents and notifications in the context of bankruptcy and reorganisation proceedings.
Under this regulation:
- Declarations of claims and reorganisation plans can now be submitted electronically.
- Notifications to creditors throughout the proceedings can be delivered via electronic means.
- When a signature is required, it must either be based on a high level of guarantee in accordance with Article 8(2) of the eIDAS Regulation, or take the form of a Qualified Electronic Signature (QES)
The regulation also reaffirms that a QES is equivalent to a handwritten signature, thereby ensuring the full legal validity and probative force of documents transmitted in this context.
This new legislative act enhances legal certainty and promotes procedural efficiency in judicial practice, particularly in commercial and insolvency matters.
Electronic signatures for legislative and regulatory acts: Draft law No. 8560
Draft law No. 8560, introduced in May 2025, aims to extend the legal framework to cover the use of electronic signatures for legislative and regulatory acts. This includes the Grand Duke’s signature, as well as the signatures of all other parties involved in the normative process -ministers, Parliament, the Council of State, and other institutions.
This Draft law addresses a legal gap by explicitly recognising the validity of electronic signatures in the adoption of binding legal texts, provided that such signatures meet the technical and legal standards of a Qualified Electronic Signature under eIDAS.
In its advisory opinion issued in February 2025, the Council of State emphasised the importance of adopting a specific legal framework for electronic signatures in the legislative and regulatory domain, given its distinct nature and the complexity of the normative procedure. This observation has been considered: Draft law No.8560 is indeed distinct from both the Law of 4 June 2025 on electronic signatures of acts in administrative matters and the amended Law of 14 August 2000 relating to electronic commerce, and is specifically dedicated to this purpose.
A short recap on various types of electronic signature under eIDAS
The eIDAS Regulation (EU) No.910/2014, amended by the "eIDAS 2.0" Regulation No. 2024/1183, provides a harmonised legal framework across the European Union for electronic identification and trust services. It recognises three levels of electronic signatures, each offering different levels of legal protection:
- A simple electronic signature (SES): this can be a scanned image of a signature, a typed name, or a “click-to-sign”. It has limited evidentiary value and no guaranteed identity verification.
- An advanced electronic signature (AES): this is uniquely linked to the signatory and capable of detecting changes to the signed date, but does not require a qualified certificate.
- A qualified electronic signature (QES): the highest level, based on a qualified certificate issued by a trusted service provider and created using a secure signature device. It is the only signature type with the same legal effect as a handwritten signature across all EU Member States (article 25 (2) eIDAS Regulation (UE) No. 910/2014)
Similarly, a qualified electronic seal applies to legal entities (public administrations, ministries…), and ensures the authenticity and integrity of official documents
Conclusion
Luxembourg is building a robust and unified legal framework for electronic signatures that spans administrative, legislative, and judicial areas, while also supporting digital interactions with the private sector.
With the Law of 4 June 2025 now in force, and the Grand-Ducal Regulation of 4 July 2025 providing crucial support for digital communication in business restructuring and liquidation procedures, the foundation for a paperless state is in place. While not yet adopted, Draft Law No. 8560, is poised to complete the framework by formally enabling digital authentication for law-making processes.
These developments form a coherent and forward-thinking strategy that positions Luxembourg at the forefront of the EU’s digital transformation, paving the way for future initiatives like the European Digital Identity Wallet (EUDI Wallet).
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