On 17 December 2025, the Luxembourg Parliament adopted the law of 19 December 2025 establishing a quantitative target for gender balance among directors of listed companies with a view to transposing Directive (EU) 2022/2381 (the “Gender Balance Law“). For those who have been following this legislative journey since the draft law stage, the enacted text remains largely faithful to the draft law, while introducing some notable refinements, particularly around enforcement mechanisms. For listed companies, adoption of the Gender Balance Law marks the point at which gender balance becomes a governance and enforcement issue, rather than a policy aspiration.

Scope and core requirements

We first covered the draft law in our April 2025 newsletter, available here. As a refresher on the scope and core requirements:

• The Gender Balance Law applies to all companies whose registered office is in Luxembourg and whose shares are admitted to trading on a regulated market in one or more EU Member States. However, in alignment with the EU Directive, listed companies that qualify as micro, small, and medium-sized enterprises (SMEs) are excluded from its scope.
• The central requirement: at least 33% of board positions, both executive and non-executive, must be held by the under-represented gender by 30 June 2026.
• The CSSF has been designated as the competent authority, tasked with overseeing compliance, collecting data, and publishing an annual list of companies that meet the target. The CSSF will work alongside the gender equality observatory (established under the Law of 7 November 2024) to monitor progress and promote best practices.

The Gender Balance Law entered into force on 23 December 2025 and will remain in force until 31 December 2038.