Vote by Luxembourg Parliament on the amendment to the Payment Services Law of 2009 implementing the ICTr Regulation

On 2 April 2025, the Parliament of the Grand Duchy of Luxembourg (“Luxembourg”) passed Bill 8460 aimed at amending the Payment Services Law of 2009¹ and implementing the ICTr Regulation² (the “Law”).

This marks the final step in the implementation of the European framework on instant credit transfers in Luxembourg. The date of publication of the Law in the Luxembourg official journal will determine the date of its application.

It is important to note that the Law introduces a system of sanctions applicable to payment service providers which fail to fulfil their legal obligations with regard to instant credit transfers as provided for by the amended SEPA Regulation³. The Law lists obligations that are subject to administrative penalties and measures, including warnings, reprimands, injunctions to cease a breach and fines of between EUR 250 and EUR 250,000. Infringements of Article 5d of the amended SEPA Regulation relating to the service ensuring verification and screening of targeted financial restrictive measures, are subject to more severe fines, notably:

• in the case of a legal person, administrative fines of a maximum of at least 10% of its total annual net turnover in the preceding financial year; and
• in the case of a natural person, administrative fines of a maximum of at least EUR 5,000,000.

This regime represents a new development compared to the existing administrative sanction regime under the Payment Services Law of 2009 (set out in Article 46), which only permitted the imposition by the CSSF of an administrative fine ranging from EUR 125 to EUR 12,500 on individuals responsible for the administration or management of payment institutions and electronic money institutions in specific instances of breaches.

For further details on the ICTr Regulation framework, please refer to our previously published newsflashes dedicated to this topic: 

• Regulatory update on payment reporting obligations and on Central Bank accounts for Non-Bank PSPs and CASPs dated 10 March 2025,  
• Bill of law amending the Payment Services Law and implementing the ICTr Regulation dated 2 December 2024, and
• New Regulation on Instant Credit Transfers – Key takeaways dated 4 June 2024.