EV charging point requirements for company car parks in Luxembourg (2026)

Luxembourg does not require every company to install charging points in its car park: today the obligation applies to new and substantially transformed non-residential buildings, depending on the number of parking spaces. The Grand-Ducal regulation of 9 June 2021 requires pre-equipment for one space in four, one charging point from 11 spaces, and three charging points per block of 20 spaces above 20, with smart charge management.

This guide is for fleet managers, facility managers and finance teams. It sets out what is mandatory now, with a calculation table by car park size, what the recast EU directive (EU) 2024/1275 will add, who pays between landlord and tenant, how installation works, how chargers are taxed, and how to comply without oversizing the car park when many drivers can charge at home. Voltaback handles home charging of company cars for more than 200 companies and complements workplace charging without any extra hardware.

The current rule in Luxembourg

The reference text is the amended Grand-Ducal regulation of 9 June 2021 on the energy performance of buildings (RGD 2021), in force since 1 July 2021. For "functional" buildings (offices, retail, industrial and administrative buildings, as opposed to residential), Annex II, chapter 1.11, sets minimum requirements for charging devices.

The principle: indoor and outdoor parking spaces must be designed so that a charging device can be added later. The regulation then sets minimum numbers.

Source: RGD of 9 June 2021, Legilux and Ministry of the Economy FAQ on the RGD 2021, functional buildings.

Minimum requirements by car park size

The total number of mandatory charging points is capped at 25 per functional building. Each charger installed above the minimum counts as a pre-equipped space.

Calculation table: how much for your car park?

The minimum numbers follow the table in the ministry's FAQ. From 21 spaces, charging points are rounded down: 3 per 20 spaces is 15 % of spaces, with a minimum of 3.

The step from 20 to 21 spaces is the most expensive: one charging point becomes three, and charge management becomes mandatory. If you are planning a new building with 21 to 25 spaces, look at this threshold deliberately.

Charging point or charging station: what is counted?

What counts are charging points, meaning connectors where one vehicle can charge at a time. A twin charging station with two connectors serving two spaces simultaneously usually provides two charging points. Check with your designer how stations are counted in the energy performance file before ordering hardware.

Pre-cabling or two ducts: what does it mean?

Pre-equipment can take two forms, depending on the wiring concept. Either pre-cabling already run to the space, or two empty ducts: one for the future power cable to the main distribution board, one for a data cable to the meter cabinet or the charge management system.

The regulation also requires a data link between the telecom operator's termination point and the main board, plus free space in the distribution boards for future protective devices. In short, adding chargers later should not mean breaking walls.

Smart charge management above 20 spaces

Above 20 spaces, a smart charge management system is mandatory. It controls all charging points behind one grid connection so that simultaneous power draw never exceeds the capacity made available by the grid operator. It must be able to manage at least the number of mandatory charging points.

That is good news for the budget: you do not have to size the grid connection for every charger running at full power at the same time.

Which buildings are covered?

The requirements apply to new functional buildings and, in case of substantial modification or transformation, to the modified parts. Simple extensions of functional buildings are not covered by the charging requirements (article 9, paragraph 1).

An existing office building that has not been transformed is therefore not required by the RGD 2021 to install chargers today. That is exactly what the 2024 EU directive changes.

Special cases that often raise questions

• Extension of an office building: no charging requirement under article 9, paragraph 1, even if new spaces are created.
• Substantial transformation: the requirements apply to the modified parts. If the underground car park is rebuilt, its spaces are covered.
• Indoor and outdoor spaces: both are added together.
• Mixed-use buildings: offices on the lower floors and flats above fall under two sets of rules; settle with your designer which spaces belong to the functional part.

What the recast EPBD (EU) 2024/1275 brings

The recast Energy Performance of Buildings Directive tightens the rules significantly. Article 14 provides, among other things:

• New non-residential buildings or major renovations with more than 5 spaces: at least one charging point per 5 spaces, pre-cabling for at least 50 % of spaces and ducting for the rest.
• New office buildings or major renovations with more than 5 spaces: at least one charging point per 2 spaces.
• All non-residential buildings with more than 20 spaces, existing ones included, by 1 January 2027: one charging point per 10 spaces, or ducting for at least 50 % of spaces.
• Public buildings: pre-cabling for at least 50 % of spaces by 1 January 2033.

The directive also expects new charging points to support smart charging. Member States had to transpose it by 29 May 2026. At the time of writing, we found no Luxembourg text published in the Official Journal that transposes article 14. The EU thresholds show the direction of travel, but only texts published on Legilux are binding: check the status before starting works.

Sources: Directive (EU) 2024/1275, EUR-Lex, European Parliament Legislative Observatory.

Worked example: a 120-space head office in Kirchberg

The gap is large for a new office building. For an existing building, the ducting option leaves real room for manoeuvre.

The timeline at a glance

Until a Luxembourg transposing text is published, the RGD 2021 remains the binding basis. The directive's dates, however, show what owners must prepare for.

Landlord or tenant: who has to install?

The requirement attaches to the building and falls on whoever builds or substantially transforms it, in practice the owner or developer. Many companies in Kirchberg, Cloche d'Or or Belval rent their offices: they do not have to pre-cable a new building themselves, but they inherit whatever the landlord has provided.

For existing buildings, the 2027 rule also targets the building. Cost sharing will depend on the transposing text and, in practice, on the lease. Three useful steps:

1. Review the lease: works clause, access to the main board, available power, use of the parking spaces.
2. Ask the landlord for its 2027 plan before funding chargers it may have to install anyway.
3. Agree in writing on ownership of the chargers, maintenance and what happens at the end of the lease.

Existing buildings from 2027: ducts or charging points?

For existing non-residential buildings with more than 20 spaces, the directive offers a choice: one charging point per 10 spaces, or ducting for at least 50 % of spaces. For an owner, this is a real trade-off.

• Ducts cost less upfront, carry no running costs and leave the tenant free to choose the hardware. But they deliver no electricity today.
• Charging points cost hardware, connection capacity, back-end software and maintenance, but make the building immediately more attractive to tenants with an electric fleet.

For a company that rents, the question is simpler: a landlord who only lays ducts leaves the decision on charging points to you. Then the actual needs of your drivers count, not the quota.

Questions to ask before signing an office lease

Companies often move offices more easily than they renovate them. When you visit a building in Kirchberg, Cloche d'Or, Belval or elsewhere, these questions save expensive surprises:

• How many spaces does the car park have, and how many are allocated to you?
• How many are pre-equipped, and how many already have a charging point?
• Is smart charge management in place, and which back-end does it use?
• What connection capacity is reserved for charging, and can it be increased?
• Who owns, maintains and pays for the existing chargers, and how is electricity billed to tenants?
• What is the landlord's plan for the EU 2027 deadline, and will its cost be passed on through service charges?
• May you install your own chargers, and must they be removed when you leave?

Get the answers in writing and attach them to the lease. A building with pre-equipment and charge management already in place lets you add points as your fleet grows, without new works.

And at home: what applies in residential buildings?

Many drivers, especially residents in the city, live in apartment buildings. New residential buildings have had their own pre-equipment and charge management requirements since 2021; they concern developers, not employers. Source: Luxtoday, charging points in residential buildings.

In an existing co-ownership, Luxembourg has no automatic right to a charging point. Under the amended law of 16 May 1975 on co-ownership:

• an individual charger installed by one or more co-owners at their own cost, affecting common parts: absolute majority of all shares;
• a collective installation paid by the co-ownership, or a power increase: double majority;
• choice of provider and budget: simple majority.

Source: Klima-Agence, practical sheet on charging infrastructure in residences. For drivers whose general meeting says no, the office charging point remains the sensible complement.

Installing chargers in the car park: the steps

Always an approved electrician

Every charger must be installed by an approved electrician (électricien agréé), listed by the Fédération du Génie Technique. Preparatory works follow the grid operator's technical connection conditions.

The grid operator request

A prior request is needed for any AC or DC charger connected to the low or medium voltage grid with a power of 7 kW or more three-phase or more than 4.6 kW single-phase. It goes through the myCreos portal at Creos, or the local operator (Diekirch, Ettelbruck, Sudstroum). After the works, the electrician records the installation in the Smarty PRO app and notifies completion.

Source: Creos, je recharge ma voiture.

Controllable chargers and OCPP

Above 20 spaces, smart charge management is mandatory. Choose chargers that support an open protocol such as OCPP, so you can switch back-end provider without replacing hardware. For private charger subsidies, the 2026 scheme also announces that smart chargers will have to comply with ISO 15118-20 from 2027: a clear signal of where the market is heading.

7, 11 or 22 kW: which power for staff?

Staff cars stay parked for hours, so high power is rarely useful. A three-phase 11 kW point adds roughly 60 km of range per hour to a car using 18 kWh/100 km, enough to cover a typical commute in one to two hours. A 22 kW point only helps if the car's on-board charger accepts 22 kW in AC, which many models do not; otherwise the car charges at 11 kW anyway. A 7 kW point is often enough for cars parked all day.

Behind a charge management system, the installed power matters less than the total capacity reserved for charging: twenty 11 kW points can share a much smaller connection, as long as the cars do not all need a full battery at the same moment. Size the connection on the energy actually needed per day, not on the sum of the chargers' nameplate power.

What drives the bill

Without quoting prices that vary from site to site, the cost of a car park project depends on five items:

• distance between the main board and the spaces, which sets cable length and trenching;
• available connection capacity, and whether the grid connection must be increased;
• charger power: 11 kW AC is enough for cars parked all day; DC fast charging is rarely justified for staff;
• charge management and back-end software, with a recurring subscription;
• maintenance and access management over the years.

Ask for at least three quotes on the same specification, separating pre-equipment, charging points and software. The steps from specification to commissioning are in our guide to installing charging points at work, and funding options in subsidies for workplace charging points. For the technical vocabulary, see EV charging infrastructure explained.

How workplace chargers are treated for tax

Charging points in the company car park are separate assets, depreciated over their own useful life, distinct from the cars. Hardware, installation and cabling form the acquisition cost; grid reinforcement may belong to the building depending on how it is done.

As tangible assets other than buildings, charging stations can in principle qualify for the 12 % investment tax credit. For investments that protect the environment or save energy, Article 32bis of the income tax law (L.I.R.) provides special depreciation of up to 80 % and a credit rate raised to 14 %, subject to certification by the competent administration. Whether a charging project qualifies depends on the project itself: check with your fiduciary before ordering. Source: ACD, investment tax credit.

Electricity charged on site is invoiced to the company; its 8 % VAT is recoverable under the normal rules for a company with a taxable activity.

Charging employees' private cars at work

Once chargers are in the car park, employees with a private EV will ask to use them. Two points deserve a clear rule.

Tax. For a company car, the electricity charged on site is the car's energy, like fuel. For an employee's private EV charged free of charge, we found no specific Luxembourg exemption: under the income tax law, a benefit granted to an employee is in principle taxable at its usual value. In practice it is rarely valued, but do not present it as tax-free without your fiduciary's opinion. Many companies avoid the question by billing private charging at cost through the back-end.

Priority. Decide who comes first: pool cars, company cars of drivers without home charging, visitors, then private cars. Without a rule, the same early arrivals occupy the points every day.

A workplace charging policy that avoids conflicts

A short written policy prevents most disputes. It should cover:

• Access: who may use the points, with which badge, and at what times.
• Rotation: maximum duration or the duty to move the car once charged; a car parked all day on a charger blocks others.
• Billing: free for company cars, at cost for private cars, or another explicit rule.
• Faults: whom to call, and how quickly a broken point is repaired.
• Data: charging badges and back-end logs show who charged when. This is personal data under the GDPR: collect only what billing needs, set a retention period and inform the staff delegation if the data could be used to monitor staff.

Know where each company car charges

On-site chargers, home charging and public networks all feed the same cars. Without a per-car view, the company pays three times for energy without knowing the split: the site electricity bill, home charging claims and charging card statements. Measuring the kWh each company car takes at the office, at home and on the road, without geolocating anyone, shows whether the office points are really used, by whom, and whether more are worth building. It is also the evidence your fiduciary needs to treat company car electricity correctly.

What are the penalties?

We found no specific fine for charging points in the RGD 2021 or its FAQ. The minimum requirements are built into the energy performance calculation that accompanies a construction or transformation project: a non-compliant file mainly leads to permitting and handover problems, and to more expensive retrofits later.

For the 2027 obligation on existing buildings, control and penalties will depend on the transposing text. Do not rely on any fine amount until it is published in the Official Journal.

Building obligation and fleet: two different things

The charging point obligation concerns buildings, not fleets. Private companies in Luxembourg have no quota on how many of their company cars must be electric. Clean vehicle requirements in procurement concern public buyers.

What drives fleet electrification is mainly the benefit in kind: 0.5 % or 0.6 % of the list price per month for an electric car, against 2 % for combustion cars and plug-in hybrids first registered from 2025. A company can therefore meet the building obligation without a single electric company car, or run a fully electric fleet while its rented existing building needs no charging point today.

4 common misconceptions

1. "We need one charger per employee who drives electric." Wrong. Thresholds count the building's parking spaces, not employees or company cars.
2. "All existing offices must already be equipped." Not yet. The RGD 2021 covers new builds and substantial transformations; the 2027 deadline for existing buildings comes from the EU directive and awaits transposition.
3. "The employer must install a charger at drivers' homes." Wrong. No Luxembourg text requires it, not even for an electric company car.
4. "A few office chargers are enough to electrify the fleet." Rarely. A company car spends around twelve hours a day at the driver's home; that is where charging is simplest and cheapest.

Compliance in four steps

1. Classify the building: new build, substantial transformation, extension or existing? Count indoor and outdoor spaces.
2. Calculate the minimum: pre-equipment, mandatory charging points and charge management from the table above; for existing buildings, keep the directive's 2027 deadline in view.
3. Clarify roles: who is the developer, who is the tenant, who pays, who owns the charging points? In writing, in the lease or an addendum.
4. Compare with actual needs: how many drivers cannot charge at home? Only then decide on charging points above the minimum.

The essentials in one table

What this means for your company: size to real needs

According to the Arval Barometer 2026 (300 companies in Luxembourg), 86 % use or plan on-site charging, 65 % public networks and only 21 % home charging. Yet 70 % still cite charging as a difficulty. Source: Paperjam, Arval Barometer 2026.

Luxembourg's workforce explains the imbalance and points to the solution. About 49 % of employees are cross-border workers living in Belgium, Germany or France. Their company car spends the night across the border: one night of home charging easily covers a round trip from Arlon, Trier or Thionville to the capital. Source: IGSS employment dashboard, March 2026.

A sound approach is to:

• meet the regulatory minimum in the car park (pre-equipment, mandatory points, charge management);
• reserve office chargers for visitors, pool cars and drivers with no option at home;
• organise home charging of company cars, with accurate reimbursement.

Every space equipped beyond need costs hardware, connection capacity and back-end fees, for a charger that will often sit idle. Our page on the alternative to a home charger for employees shows how to equip each driver to fit their actual need, and the guide to managing and reimbursing fleet home charging covers the HR and payroll side.

How many points beyond the minimum? A simple method

Energy is rarely the constraint; occupancy is. A commuter driving 60 km a day at 18 kWh/100 km needs about 11 kWh a day. An 11 kW AC point delivers that in about one hour, and could in theory deliver about 88 kWh over an 8-hour working day. In practice, cars are rarely moved during the day, so count one point per car that really depends on office charging, then reduce it if you organise rotation.

The cars that depend on office charging are those of drivers with no charging option at home, plus pool cars, plus a margin for visitors. Everyone else charges at home overnight.

Case study: 120 spaces, 60 electric company cars

A company moves into a new building with 120 spaces and has 60 electric company cars. Does it need 60 charging points?

• RGD 2021 obligation: 30 pre-equipped spaces and 18 charging points with charge management. That is the minimum, whatever the number of company cars.
• Need: of the 60 drivers, 30 are cross-border workers living in a house with parking, 15 are residents also able to charge at home; 15 cannot charge at home.
• Result: the 18 mandatory points cover the 15 drivers without home charging, plus pool cars and visitors. The other 45 charge at home at night and are reimbursed at real cost.

Instead of building 60 charging points, the company stays at the legal minimum, and the 30 pre-equipped spaces secure later expansion if the drivers' profile changes.

Reimbursing home charging at real cost

Home charging raises one real question: how much to reimburse? Luxembourg has no official flat rate per kWh. A kWh charged at night costs about €0.19 for a resident on a dual-rate offer, but about €0.24 at night for a Belgian cross-border worker with a dual-rate meter and about €0.32 for a German one. A single price under-reimburses some drivers and over-reimburses others.

Voltaback measures every charge of the company car and reimburses it at the real price of the employee's own contract, with no box and no connected charger. Voltaback relies on the home's MID-certified meter, not on a standalone cable meter. In practice, this electricity is generally treated as covered by the car's flat-rate benefit in kind when it is reimbursed at measured real cost; have your fiduciary confirm this treatment.

• 100 % software, more than 48 car brands connected.
• Measurement audited by an independent third party: 1.22 % relative error.
• ISO 27001 certified since 2 December 2025, GDPR compliant.
• The company never receives drivers' geolocation.
• Monthly export ready to import into your payroll software.

For the wider fleet transition, read our article on greening your company fleet. For the car park chargers themselves, Voltaback does not install but can help you get installer quotes: see charger installation.

Comply, and equip your drivers to fit their real need

The regulatory minimum for your car park is clear for new buildings, and the 2027 EU deadline can be prepared now. The rest of the charging can happen where the car already sleeps, at a much lower cost. To organise home charging of your company cars and reimburse it at real cost, contact the Voltaback team.