According to the CCDH, the situation of human rights defenders and their enabling environment remains generally open. Luxembourg has, at least in theory, some good practices such as the multistakeholder working groups in the context of developing and implementing national action plans. Moreover, the Ministry of Justice launched its project to financially support CSOs again, this time focusing on women and/or children.
However, as already mentioned in the 2025 report, there are some signs of a narrowing or restricted civic space.
Structual challenges for civil society organisations and human rights defenders
The CCDH has identified structural challenges for CSOs and HRDs, relating among others to lack of adequate funding, barriers in access to law- and policy-making processes and to meaningful public consultations, as well as to existing laws and/or policies which negatively impact on the right to association or assembly and the right to protest.
Lack of consideration of CSO input by authorities
In practice, CSO input is often not adequately taken into account as regularly pointed out by the CCDH in its rule of law reports. While there have been isolated good practices (e.g. the consultation process of the “avant-projet de loi” aimed at creating a legislative framework for public assemblies such as protests mentioned below), the CCDH still has not noticed any substantial improvements in this regard.
Limited access to justice
Access to justice via legal action is still insufficient. In Luxembourg, the right to take legal action for a CSO is rather limited and conditional on the existence of a standing and vested interest in taking action. These conditions are difficult to meet for an association when it acts in defence of a collective interest. The legislative and regulatory framework needs to be revised urgently, while also foreseeing sufficient support (financial, guidance, …) for CSOs. This has recently been confirmed by a research paper of the parliamentary research unit. It found that the “Luxembourg legal framework governing the right of associations to take legal action could be deemed incompatible with Article 6(1) of the European Convention on Human Rights, which guarantees the right of access to a court, as it is neither sufficiently open nor sufficiently predictable” and that the “lack of coherence between sector‑specific legislation and the inequalities between accredited and non‑accredited associations may give rise to a risk of unconstitutionality, particularly with regard to the principle of equality before the law, protected by Article 15 of the Constitution”.
Restructuration of the Luxembourgish CSO landscape
Following the dismantling of one of Luxembourg’s largest civil society organisation (Caritas Luxembourg), at least 28 NGOs have formalised their collaboration through the creation of “Voĉo”, a collective aimed at filling the void left by the disappearance of one of the country’s critical voices and actors in political advocacy.
Excessive administrative controls
In the 2025 report, the CCDH noted that the municipality of Luxembourg City contractually required the NGOs it collaborates with to ensure that “any communication by the association with the press about [their project] must be carried out in consultation with the City of Luxembourg.” While the City of Luxembourg appears to intend to remove this clause from future contracts, the existing agreements will remain in force until they are renewed. Although journalists’ associations have criticised these clauses, the CSO in question - “Hëllef um Terrain (HUT)”, the successor organisation to Caritas Luxembourg - does not seem to consider them problematic. As already mentioned in the 2025 report, there are fears that more and more critical civil society voices might disappear.
Limited access to information and documents
As reported by the CCDH, access to information remains too limited for journalists, CSOs and HRDs. The draft bill 8421 on the promotion of professional journalism and democratic debate referred to in the CCDH’s 2025 report, is still pending in the legislative process. While the CCDH has not done a full assessment of this legislative proposal yet, it has reservations regarding its potential to genuinely improve access to official documents, as an initial analysis suggests that the proposed changes may be rather superficial or cosmetic in nature.
The administrative court of appeals ruled in favour of a CSO that challenged the City of Luxembourg’s refusal to disclose documents. Among other arguments, the municipality claimed that granting access to documents should be the exception and keeping them confidential the rule. This appears to remain the prevailing mindset within Luxembourgish authorities. The regulatory framework for CSOs has been modified. The government plans to assess the impact of these changes in 2027. Other reforms of the cooperation and development policy of Luxembourg and the relevant CSOs are ongoing. The CCDH has not analysed or monitored these reforms due to lack of resources. However, it notes that some CSOs have voiced concerns over these reforms (also see the meeting of the Cercle des ONGs with the parliament and the statement of the collective "Voco").
Authorities’ attempts to limit the freedom of assembly
The government was working on a legislation aimed at limiting the freedom of assembly. The CCDH issued advisory opinions in 2024 and 2025 (which are not publicly available), reminding the government that it should first and foremost strengthen the right to protest, instead of creating unnecessary barriers and sanctions. Recently, the government announced the withdrawal of said legislation. While the CCDH welcomes that the foreseen restrictions will not enter into force, it regrets that the current situation remains unchanged: assembly rules are defined on municipal level, some of which are most likely incompatible with human rights standards as they are too restrictive.
Attempts to exclude LGBTIQA+ topics from minors’ education curricula
A petition that aimed to exclude LGBTIQA+ topics from the education of minors gained a lot of weight and led to a “counter petition” to increase the LGBTIQA+ subjects within the education of minors. The CCDH published a statement highlighting the importance of including LGBTIQA+ topics in education in order to foster diversity and promote the wellbeing and mental health of young people. The CCDH also emphasised other important measures to be taken and recalled the State’s obligations under European and international law regarding access to LGBTIQA+ topics. A debate was held in parliament, where a majority of members believed LGBTIQA+ issues should not be excluded from education, while ensuring that they are adapted to the age of the students.
Threats to civil society organisations and human rights defenders
The CCDH has reported that CSOs and HRDs sometimes face threats such as verbal attacks, negative narratives by public authorities, and online threats or harassment. Since the CCDH does not have a complaint mechanism mandate, it did not directly or formally find any such evidence.
The CCDH was, however, able to note the following:
LGBTQIA+ HRDs
There have been reports about threats and attacks in the past, notably aimed at LGBTIQA+ HRDs. This has reportedly led to criminal investigations against some users who propagated hateful messages online.
Business and human rights
A formal complaint was lodged before the Luxembourgish OECD National Contact Point for responsible business conduct against a company allegedly involved in the disappearance of human rights activists in Mexico.
Negative narratives and adverse conditions for HRDs and CSOs
More generally, the CCDH has noticed that some public authorities adopt negative narratives on civil society and/or HRDs. There is a certain reluctance to strengthen CSO participation in the decision-making process or to confer greater responsibilities to CSOs.
There have been reports by CSOs that HRDs and activists are becoming increasingly worried of negative consequences such as censorship, pressure at the workplace, dismissal, harassment, public shaming, and the sharing of personal information such as phone numbers, addresses, and workplaces, as well as death and torture threats.