CSSF press release on entry into application of new rules introduced by Directive (EU) 2024/825 from 27 September 2026

CSSF press release on entry into application of new rules introduced by Directive (EU) 2024/825 from 27 September 2026

On 23 September 2026, the CSSF published a press release alerting market participants to the entry into application of the new rules introduced by Directive (EU) 2024/825 of 28 February 2024 (ECGT Directive), which amends Directives 2005/29/EC (Unfair Commercial Practices Directive) and 2011/83/EU (Consumer Rights Directive), on 27 September 2026.

The ECGT Directive has been implemented into Luxembourg law by the law of 9 June 2026 amending the Consumer Code. From 27 September 2026, commercial practices – including environmental claims and the use of sustainability labels – must comply with the new requirements, irrespective of whether the products which are in scope are already available on the market.

What the CSSF says

The CSSF states that the ECGT Directive introduces new requirements in relation to sustainability-related consumer-facing communications.

The CSSF expects financial market participants to (i) take due account of these requirements, and (ii) ensure that consumer-facing sustainability-related claims are clear, accurate and duly substantiated, and that requirements already imposed by law are not presented as a distinctive sustainability feature.

In practice, the new requirements may need to be considered alongside sector-specific rules already governing the same communication, where the recipient qualifies as a consumer under Luxembourg law.

Why this matters now

With the entry into application now imminent, financial market participants whose products are distributed to consumers should take the necessary steps to assess whether their consumer-facing commercial practices and communications fall within the scope of the relevant requirement and, where applicable, stress-test their existing commercial practices against the new rules.