Luxembourg’s Anti-Corruption Progress and GRECO Compliance: An Overview of Rounds 1 to 6

Luxembourg benefits from a strong international reputation for public integrity, having progressively strengthened its anti-corruption laws and institutional frameworks over successive evaluation cycles by the Council of Europe’s Group of States against Corruption (GRECO).

However, findings across evaluation rounds highlight that high public trust and strong statutory foundations are undercut by a reliance on informal governance practices, the lack of an overarching national anti-corruption strategy, significant vulnerabilities in public procurement, and persistent statistical blind spots in monitoring oversight and judicial tracking.

Launched in March 2025, GRECO’s 6th Evaluation Round extends this monitoring to the sub-national level, examining anti-corruption frameworks within local administrations where municipal autonomy in urban planning and procurement has often operated under informal trust-based practices. Following an on-site visit to Luxembourg City and Dudelange in September 2025 to review local standards of conduct, asset disclosures, and monitoring mechanisms, GRECO formally adopted Luxembourg’s report at its 103rd Plenary in June 2026, with public release following in September 2026. The latest report calls directly on national authorities to implement 13 targeted recommendations, covering measures such as adopting an overarching national anti-corruption strategy, codifying municipal ethics, and resourcing procurement oversight. The central government is further tasked with disseminating these findings nationwide to help all sub-national authorities resolve similar regulatory gaps, with Luxembourg required to report back to GRECO on its progress by 31 December 2027.

This policy brief traces Luxembourg’s anti-corruption trajectory across six GRECO evaluation rounds, detailing statutory progress alongside vulnerabilities in parliamentary lobbying, executive revolving doors, civil servants' secondary paid activities, municipal urban planning, public procurement, and pervasive statistical blind spots. It concludes that while significant progress has been made to expand the country’s anti-corruption framework, producing notable achievements such as specialised financial crime prosecution divisions (Parquet économique et financier), an updated ministerial Code of Conduct for top executive functions, expanded resources for the General Police Inspectorate (IGP), and voluntary sub-national integrity initiatives, Luxembourg must now bridge the gap between statutory reform and practical implementation through an inclusive, evidence-based, and measurable national strategy under the 2026 EU Directive and a stronger, enforceable framework for accountability.

1. Statutory and Institutional Framework (GRECO Mandate)

Established in 1999 under the Council of Europe Guiding Principles against Corruption (Resolution (97) 24), GRECO monitors 48 member states to identify institutional vulnerabilities and drive legislative reform through peer evaluations. Luxembourg’s evaluation history tracks its gradual transition from a reactive anti-corruption model to a codified integrity framework.

Overview of GRECO Evaluation Cycles

2. First Evaluation Round (2001–2005): Institutional Specialisation and Law Enforcement

The GRECO First Round Evaluation Report on Luxembourg (2001) assessed national compliance against key Council of Europe principles: independence of anti-corruption authorities (GPC 3), specialisation and resourcing (GPC 7), and statutory immunities (GPC 6).

Context and Legal Framework

At the time of GRECO’s review, Luxembourg was widely regarded as a low-corruption jurisdiction. However, its legal framework was significantly narrower than today: criminalisation applied strictly to basic public-sector bribery, legal entities could not be held criminally liable, and prosecutions for corruption as a predicate money laundering offence were rare. Recognising these gaps, Luxembourg initiated a reform programme to align its Criminal Code with international standards, an effort GRECO welcomed. Regarding statutory immunities (GPC 6), GRECO concluded that while formal immunities applied to the Grand Duke and Members of Parliament, they did not unduly impede corruption investigations.

Key Vulnerabilities and Overall Findings

GRECO concluded that while Luxembourg possessed solid foundations, it underestimated underlying risks and lacked the specialised structures and public awareness needed for a comprehensive anti-corruption strategy. Specific vulnerabilities included:

• Operational Constraints: A lack of dedicated anti-corruption units within law enforcement and financial intelligence, alongside restricted powers for communications surveillance and undercover operations.
• Regulatory Gaps: An absence of rules governing political party financing and statutory loopholes in civil service conflict-of-interest rules.
• Transparency Deficits: Opaque asset disclosure requirements for public officials and limited investigative media coverage.

To address these gaps, GRECO urged Luxembourg to modernise its Criminal Code, expand institutional capacity, improve transparency, support international investigations, and foster institutional vigilance through targeted awareness campaigns for civil servants and the public.

Reform Delivery & Compliance Status

Following the evaluation, GRECO issued 12 recommendations aimed at strengthening prevention, detection, and prosecution. Progress was reviewed through the Compliance Report 2003; Addendum 2005, revealing a mixed implementation record:

3. Second Evaluation Round (2004–2008): Proceeds of Crime, Public Integrity, and Legal Persons

The GRECO Second Round Evaluation Report on Luxembourg (2004) evaluated national compliance across three thematic areas aligned with the Criminal Law Convention on Corruption (ETS No. 173): proceeds of corruption and asset recovery (Theme I), integrity and oversight in public administration (Theme II), and corporate criminal liability and fiscal controls (Theme III).

Context and Scope

While Luxembourg maintained high international standing and low levels of perceived public sector corruption, GRECO’s assessment highlighted structural gaps in preventive and legislative frameworks. The review focused on the practical availability of provisional seizure and asset confiscation tools, conflict-of-interest safeguards for civil servants, corporate accountability mechanisms, and reporting duties for private financial actors.

Key Vulnerabilities and Overall Findings

GRECO cautioned that reliance on a high-trust environment could obscure systemic vulnerabilities. The evaluation identified several structural weaknesses across the public and corporate sectors:

• Asset Recovery Framework: Practical application of asset confiscation and provisional seizure was limited, particularly concerning equivalent-value assets and third-party holdings.
• Ethics and Public Sector Transparency: A comprehensive national anti-corruption strategy was lacking. Rules governing civil service conflicts of interest, gifts, post-employment ("revolving doors"), and public access to administrative documents were under-developed.
• Corporate Accountability: Legal persons remained immune from criminal liability, while dedicated corruption detection guidance for external accountants and auditors was absent.

To address these vulnerabilities, GRECO urged Luxembourg to codify public integrity standards, introduce statutory corporate criminal liability, expand administrative document access, and strengthen practical asset recovery.

Reform Delivery and Compliance Status

Following the evaluation, GRECO issued 13 recommendations. Luxembourg’s progress was monitored through the Compliance Report (2006) and Addendum (2008), resulting in a gradual legislative response:

4. Third Evaluation Round (2008–2012): Offence Alignment and Political Party Financing

The GRECO Third Round Evaluation Report on Luxembourg (2008) assessed compliance across two distinct policy areas: the alignment of domestic criminal law with international conventions (Theme I) and the transparency of political party financing (Theme II).

Context and Scope

The evaluation evaluated Luxembourg’s statutory provisions against the Criminal Law Convention on Corruption (ETS No. 173) and its Additional Protocol (ETS No. 191), alongside Council of Europe standards on political funding transparency. Initial compliance assessments returned a "globally unsatisfactory" finding, reflecting substantial statutory gaps in political financing rules and legal inconsistencies in corruption offences.

Key Vulnerabilities and Overall Findings

The assessment highlighted key statutory and structural risks across both themes:

• Criminal Law Gaps (Theme I): Statutory definitions of public bribery were incomplete, trading in influence was not fully criminalised, coverage of foreign public officials remained limited, and statutory sanctions lacked practical dissuasiveness.
• Political Financing Gaps (Theme II): Luxembourg lacked a comprehensive legal framework governing political party and campaign finances. Specific deficits included an absence of donation caps, limited public disclosure of party accounts, a lack of independent supervisory oversight, and an absence of effective financial sanctions.

Reform Delivery and Compliance Status

GRECO issued 17 recommendations (7 under Theme I; 10 under Theme II). Through subsequent compliance reviews, Luxembourg delivered progress across criminal law reform, while political financing recommendations achieved partial implementation:

• Theme I: Incriminations (57% Satisfactory / 43% Partial): Legislative amendments harmonised the Criminal Code with international conventions, explicitly criminalising trading in influence and broadening definitions of foreign public officials. Practical enforcement remained limited.
• Theme II: Political Funding (20% Satisfactory / 80% Partial): The Loi du 21 décembre 2007 established the first legal framework for political party funding and accounting. However, monitoring was delegated to parliamentary bodies rather than an independent supervisor, and donation loopholes remained.

Luxembourg adopted a parliamentary Code of Conduct, launched an asset declaration framework, and introduced a public lobbying register. For the judiciary, the establishment of the independent National Judicial Council (Conseil National de la Justice) advanced following constitutional updates, providing a statutory body for judicial oversight and administration.

5. Fourth Evaluation Round (2013–2023): Parliamentary and Judicial Integrity

The GRECO Fourth Round Evaluation Report on Luxembourg (2013) marked a major policy shift toward preventive integrity frameworks governing Members of Parliament (MPs), Judges, and Prosecutors.

Context and Scope

The evaluation examined preventive safeguards across three core areas: ethical principles and codes of conduct, conflict-of-interest management, asset and interest declarations, and supervisory oversight mechanisms.

Key Vulnerabilities and Overall Findings

The assessment highlighted a structural gap between Luxembourg's high-trust environment and its formal preventive structures:

• Parliamentary Safeguards: Complete absence of an MP code of conduct, unmonitored lobbying contacts, uncodified conflict-of-interest rules, and lack of public asset and interest disclosures.
• Judicial Safeguards: Strong judicial independence coupled with informal ethical guidance, uncoordinated rules on outside activities, and delayed structural governance reforms.

GRECO emphasised that high public trust should complement, rather than substitute for, codified integrity rules, public transparency registers, and independent disciplinary systems.

Reform Delivery and Compliance Status

Luxembourg received 14 recommendations. Initial compliance reviews from 2015 to 2019 assessed progress as "globally unsatisfactory," reflecting slow statutory adoption. Between 2020 and 2023, gradual progress was recorded following key parliamentary and constitutional reforms. Sustained legislative activity resolved key parliamentary gaps, while judicial governance reforms depended on constitutional modernisation.

Key Risk Areas

• Parliamentarians: Complete absence of a parliamentary code of conduct, unmonitored lobbying activity, zero conflict-of-interest declarations, and informal oversight.
• Judicial Branch: High operational independence coupled with a lack of written ethical codes, uncoordinated outside activity rules, and delayed structural governance.

Recommendation Implementation Matrix

Luxembourg adopted a parliamentary Code of Conduct and introduced a public register for lobbying interactions. However, judicial branch reforms experienced systemic delays, relying on the long-term passage of constitutional revisions to formally construct the National Judicial Council (Conseil National de la Justice).

6. Fifth Evaluation Round (2018–Present): Executive Leadership and Law Enforcement

The GRECO Fifth Round Evaluation Report on Luxembourg (2018) focused on corruption prevention among Persons Exercising Top Executive Functions (PTEFs), including ministers and senior political appointees, and the Grand Ducal Police (Police Grand-Ducale).

Context and Scope

The evaluation assessed integrity management across the highest levels of executive authority and law enforcement. Key areas examined included conflict-of-interest regulation, post-employment ("revolving door") restrictions, transparency of lobbying activities, administrative document access, and police internal risk oversight.

Key Vulnerabilities and Implementation

GRECO addressed 21 recommendations to Luxembourg. Compliance reviews in 2020 and 2022 recorded incremental progress:

• Executive Oversight (PTEFs): Luxembourg updated the ministerial Code of Conduct, but independent monitoring and enforceable sanction mechanisms remained unlegislated. Voluntary disclosures for minister-lobbyist contacts were encouraged, but a mandatory lobbying framework was not established. The Loi du 14 septembre 2018 relative à une administration transparente established a right to administrative documents, though statutory exemptions maintained restrictive access in practice.
• Law Enforcement: The Grand Ducal Police updated internal ethics instruction, but integrated risk-assessment frameworks across operational units remained pending. Staffing and resources for the General Police Inspectorate (Inspection Générale de la Police - IGP) were expanded.

GRECO noted that risks were primarily related to institutional accountability, transparency, and oversight mechanisms rather than systemic bribery.

Reform Delivery and Compliance Status

GRECO addressed 21 recommendations to Luxembourg. Compliance reviews in 2020 and 2022 recorded incremental progress:

Central Government (PTEFs)

• Code of Conduct: Luxembourg updated the ministerial Code of Conduct, but independent monitoring and enforceable sanction mechanisms remained unlegislated.
• Transparency and Lobbying: Voluntary disclosures for minister-lobbyist contacts were encouraged, but a comprehensive mandatory lobbying framework was not established.
• Document Access: The Loi du 14 septembre 2018 relative à une administration transparente established a legal right to administrative documents, though extensive statutory exemptions maintained restrictive public access in practice.
• Post-Employment Controls: Advisory post-government employment rules were introduced, lacking an independent monitoring body to enforce compliance.

Law Enforcement (Grand Ducal Police)

• Police Integrity Code: The Grand Ducal Police updated internal ethics instruction, but integrated corruption risk-assessment frameworks across operational units remained pending.
• Inspectorate Capacity: Staffing and operational resources for the General Police Inspectorate (IGP) were expanded, though further independence measures remained in progress.

7. Sixth Evaluation Round (2025–Present): Sub-National Integrity and Municipal Governance

The GRECO Sixth Evaluation Round Report on Luxembourg was adopted at GRECO’s 103rd Plenary Meeting in Strasbourg (June 2026) and published in September 2026. This evaluation marked a major milestone by extending anti-corruption scrutiny to the sub-national level. The evaluation team evaluated Luxembourg’s national framework as well as two case-study municipalities that volunteered for review: Luxembourg City (the capital and largest municipality) and Dudelange (the fourth largest municipality).

Context and Scope

While Luxembourg benefits from decentralised municipal self-government enshrined in Article 121 of the Constitution and the European Charter of Local Self-Government, local authorities hold significant discretionary spending power and regulatory autonomy. The evaluation examined national oversight mechanisms, municipal risk management, codes of conduct, conflict-of-interest rules, public procurement safeguards, lobbying transparency, access to documents, external auditing, and whistleblower protection at the local level.

Key Observations of the GRECO Evaluation Team

1. Public Perception versus Local Corruption Risks

The evaluation team noted the contrast between Luxembourg’s high international standing as a low-corruption jurisdiction and the fact that among local actors, that corruption did not seem to be a major concern. High-risk sectors were explicitly identified:

• The Property and Real Estate Sector: Significant pressure on the national housing market makes municipal decisions regarding building permits, General Development Plans (Plan d'Aménagement Général - PAG), and Special Development Plans (Plan d'Aménagement Particulier - PAP) exceptionally vulnerable to undue influence, conflict of interest, and favouritism.
• Public Procurement: Municipalities operate on the front line of public contract awards without sufficient integrity safeguards.

2. Absence of a National Anti-Corruption Strategy and Statistical Deficits

Luxembourg has no overarching national anti-corruption strategy or comprehensive risk mapping covering central and municipal administrations. Work on a National Risk Assessment (NRA) began only in January 2026. Furthermore, national judicial statistics fail to track or categorize corruption cases by municipal status, making it impossible to evaluate law enforcement trends at the sub-national level systematically.

3. Governance and Visibility Deficits of COPRECO

The Corruption Prevention Committee (Comité de Prévention contre la Corruption - COPRECO), set up in 2007, operates primarily as an advisory body without public visibility, a dedicated website, or published activity reports. Crucially, COPRECO lacks representation from municipal authorities (such as SYVICOL) and civil society, restricting its ability to analyze, monitor, or disseminate anti-corruption best practices to local governments.

4. Severe Oversight and Resource Bottlenecks in Public Procurement

While the Ministry of Home Affairs (Ministère de l'Intérieur) exercises legal oversight over municipal procurement, its capacity is severely constrained. The Ministry employs only 2.5 full-time equivalent (FTE) staff members to monitor public procurement across 100 municipalities, 70 intermunicipal associations (syndicats intercommunaux), and 30 municipal public establishments. Oversight is conducted on a paper-based, sampling basis without digital risk-flagging tools. Moreover, municipal procurement procedures lack explicit conflict-of-interest declarations for evaluation board members and do not utilize integrity pacts with tenderers.

5. Uncodified Ethics and Unmonitored Secondary Activities

While Bill No. 8052 is pending in Parliament to establish rules of conduct, gift caps (€150), and interest declarations for local elected officials, municipal civil servants and employees currently operate without a consolidated, national code of conduct. Secondary paid activities of municipal staff require authorization from the college of the mayor and aldermen, but municipalities lack centralized tracking registers or systematic follow-up mechanisms, as highlighted by recent criminal convictions of municipal officials engaging in unapproved, remunerated consultancy for dozens of other communes.

6. Deficits in Document Access (CAD) and Whistleblower Protection

Despite the Law of 14 September 2018 on transparent administration, municipal practice remains restrictive. Municipalities frequently refuse or delay administrative document requests, forcing civil society associations to pursue multi-year litigation to secure disclosable files. The Commission on Access to Documents (CAD) lacks binding decision-making powers and possesses no follow-up mechanism to track municipal compliance with its opinions. Regarding whistleblowing under the Law of 16 May 2023, the presence of 22 fragmented external reporting channels creates confusion, while recent court rulings placing the burden of proof on dismissed employees demonstrate practical weaknesses in anti-retaliation protections.

Summary of GRECO’s 13 Recommendations for Round 6

GRECO addressed 13 specific recommendations to Luxembourg to strengthen sub-national integrity:

GRECO Round 6 Recommendation Architecture

Strategic Synthesis

Across a 25-year evaluation arc, Luxembourg has refined its anti-corruption framework, transitioning from narrowly defined criminal offences to a cohesive statutory architecture. Nevertheless, a persistent structural theme endures: legislative updates remain predominantly reactive, prompted primarily by GRECO compliance imperatives rather than emerging from a proactive, whole-of-government reform process aimed at strengthening public integrity.

With GRECO’s 6th Evaluation Round extending this analysis to sub-national authorities, Luxembourg faces a clear imperative: to bridge the gap between statutory reform on paper and practical implementation across all levels of governance. Delivering meaningful anti-corruption progress requires moving beyond reactive compliance by rigorously enforcing conflict-of-interest controls, resourcing independent oversight bodies, guaranteeing administrative transparency, and embedding proactive integrity safeguards throughout municipal administrations. To sustain momentum and deepen national ownership, Luxembourg must prioritise effective, nationwide execution rather than relying on external prompting from successive GRECO evaluation cycles.

GRECO’s 6th Evaluation Round serves as a critical assessment for Luxembourg. While acknowledging progress made across prior evaluation cycles, it warns against relying on informal governance, particularly at the sub-national level where unmanaged conflicts of interest and procurement risks persist. L4T emphasises the report's key concerns: the complete absence of a national anti-corruption strategy, systemic oversight and resource bottlenecks in municipal procurement, and critical data collection gaps. Judicial, administrative, and local systems consistently fail to track corruption prosecutions, conflict-of-interest recusals, civil servant secondary employment, or document access compliance, recalling issues identified as far back as Luxembourg’s 2015 UNCAC first-cycle review.

Regarding the development of Luxembourg’s national anti-corruption strategy, the response of the authorities does not suggest that they are adopting a multi-stakeholder consultative approach. Luxembourg is one of just six EU Member States facing an urgent imperative to adopt a strategic framework under the 2026 EU Anti-Corruption Directive. However, the GRECO report reveals that the Ministry of Justice intends to recruit a consultant to develop it. L4T strongly recommends adopting the good practices documented by Transparency International for the development of the national anti-corruption strategy. According to the UNODC, a national strategy is "a blueprint for a realistic, comprehensive and integrated plan for reducing corruption in that country". It is a binding political pact that requires rigorous data and broad democratic consultation, paired with clearly established implementation modalities and a robust framework for monitoring and evaluation.

Luxembourg should follow proven models from countries like the UK, France, the Czech Republic, and Bulgaria, which built their national strategies through structured, multi-stakeholder consultative processes reflective of their national contexts. It needs to bring together civil society organisations, academic experts, law enforcement, trade unions, and local government bodies from day one to establish a shared framework rooted in real-world risk mapping and measurable metrics. Luxembourg needs a collaborative architecture to ensure its national strategy drives genuine institutional reform rather than mere administrative compliance.

Key Statutory References and Primary Sources

• Council of Europe Guiding Principles against Corruption (Resolution (97) 24)
• Criminal Law Convention on Corruption (ETS No. 173)
• GRECO First Round Evaluation Report on Luxembourg (Greco Eval I Rep (2001) 4E)
• GRECO Second Round Evaluation Report on Luxembourg (Greco Eval II Rep (2003) 7E)
• GRECO Third Round Evaluation Report on Luxembourg (Greco Eval III Rep (2007) 4E)
• GRECO Fourth Round Evaluation Report on Luxembourg (Greco Eval IV Rep (2012) 6E)
• GRECO Fifth Round Evaluation Report on Luxembourg (Greco Eval V Rep (2017) 4E)
• GRECO Sixth Round Evaluation Report on Luxembourg (Greco Eval 6 Rep (2025) 4)
• Legilux: Journal Officiel du Grand-Duché de Luxembourg