25
Aug 2026
Luxembourg’s government said it cannot determine how many people live in the country without legal residency status because there is no reliable method to count them.
The response came in a written reply to a parliamentary question from Luxembourg Socialist Workers’ Party (LSAP) MP Mars Di Bartolomeo.
Invisible by definition
The government said that the lack of data is inherent in how administrative records work.
“By definition, individuals not identified by the authorities do not appear in administrative records,” the reply stated. Irregular residents are, by definition, not registered with state administrations.
Officials added that there is “no reliable or responsible method” for estimating their number.
The Directorate of Immigration records only people who enter an official procedure, excluding anyone who avoids contact with authorities.
Guesswork carries a cost
The government also rejected informal estimates based on visual impressions, saying that they are unreliable and risk unfairly targeting people based on appearance or background.
Officials considered that risk particularly serious in diverse Luxembourg and offered no alternative proxy for estimating the undocumented population.
Inspectors catch a glimpse
Workplace inspections provided some concrete figures, though the government did not treat them as representative of the wider population.
In 2025, the Labor and Mines Inspectorate (ITM) conducted more than 17,000 workplace inspections, including more than 8,300 in construction and 2,760 in manufacturing.
Inspectors identified 106 foreign nationals in an irregular situation.
The figure reflects only people encountered at inspected workplaces and cannot support a national estimate.
(Image courtesy of Chris Barbalis via Unsplash)
One sector, half the cases
Hospitality accounted for 69 of the 106 cases detected in 2025.
The pattern extends beyond one year: from 2021 to 2025, hotels, restaurants, and cafés accounted for more than half of all irregular workers identified by ITM.
Common violations included missing employment contracts, lack of social security registration, excessive working hours, and unpaid wages.
Classrooms stay out of it
Schools do not record pupils based on their parents’ residency status.
“No child can be denied the right to education because of their family’s administrative situation,” the government insisted, adding that the policy is designed to prevent discrimination or stigmatization.
As a result, the state also has no count of children living in families with irregular residency status.
(Image courtesy of Erik Mclean via Pexels)
Nobody has ever asked
The government said that Luxembourg has never commissioned a dedicated study on irregular migration.
That leaves little data beyond workplace inspections and administrative records that, by design, exclude many undocumented residents.
Policy without a number
The government’s reply highlights the limits of official data. Immigration records cover only people who approach authorities, while schools deliberately exclude parental residency status.
Workplace inspections provide snapshots rather than a representative sample. The 106 cases found during more than 17,000 inspections in 2025 therefore indicate patterns within particular sectors, not the size of Luxembourg’s undocumented population.
Hospitality remains the clearest concentration, accounting for most detected cases and drawing attention to labor abuses such as missing contracts, excessive hours and unpaid wages.
Di Bartolomeo’s question ultimately received no numerical answer, and without a dedicated study, the government maintains that no responsible estimate can be made.