Luxembourg Pays Half of an SME Consultancy Project — and Sets No Rule on Who Invoices

Most European digitalisation subsidies quietly decide who is allowed to do the work. Flanders asks providers to register. Wallonia ran a labelling scheme and then froze it. Plenty of national programmes keep an approved-supplier list and leave everyone else outside. Luxembourg's Régime PME consultancy aid does none of that — and it is worth knowing precisely, because the absence is in the legal text rather than in a brochure.

Everything below was read first-hand on 11 October 2026 in the sources themselves: the consolidated law of 9 August 2018 in the version applicable from 15 September 2026, and the grand-ducal regulation of 12 October 2018 that completes it — read in full, not skimmed. Subsidy rules move. Check the date above before you build a budget on any of this, and treat guichet.public.lu and the Ministry of the Economy as the only authority on their own scheme.

What the scheme actually pays

The aid sits in article 5 of the law, titled Aides aux services de conseil en faveur des PME — aid for consultancy services in favour of SMEs. The mechanics are short enough to state completely:

• 50% of eligible costs for micro, small and medium-sized enterprises. That is the figure in the text, not a maximum you negotiate down from.
• Eligible costs are the costs of consultancy services provided by advisers external to the beneficiary, with costs related to training excluded.
• The minimum gross aid is €1,000 for micro and small enterprises and €5,000 for medium-sized and large ones. This one trips people up: it is a floor on the aid, not on the project. At 50%, a small company needs a project of at least €2,000 to clear it, and a medium-sized company at least €10,000.
• The law sets no euro ceiling of its own. Article 1 caps the aid by reference to the thresholds in the EU general block exemption regulation, which for a consultancy project of ordinary size is far above anything you will spend. In practice the binding limits are the 50% rate and that minimum.
• Payment comes after the project is finished. The claim goes in within 12 months of the project end date, extendable by a further 12.

There is no call for proposals, no submission window, no annual envelope that closes in July. It is a standing regime, filed through MyGuichet.lu with a LuxTrust certificate or an electronic ID card.

The question that decides everything: who may invoice

If you are an SME choosing a provider — or a provider wondering whether your invoice can go into someone's file — this is the only question that matters. Here is the complete answer the legal texts give.

Article 5 defines eligible costs as the costs of consultancy services provided by conseillers extérieurs à l'entreprise bénéficiaire: advisers external to the beneficiary undertaking. That phrase is the whole specification. There is no requirement that the adviser be established in Luxembourg, registered in the Luxembourg trade register, accredited, labelled, or listed anywhere. There is no nationality condition. There is no approved-supplier panel.

That is a strong claim, so here is why it is a reading of the law rather than a failure to find the small print. Article 3 of the law delegates one specific job to a grand-ducal regulation: fixing la nomenclature des dépenses et des entreprises éligibles — the list of eligible expenses and eligible enterprises. The regulation of 12 October 2018 does exactly that and nothing more. Its article 1 lists which expenses are eligible. Its article 2 lists which enterprises are excluded. Both lists concern the beneficiary. The regulation is about four thousand characters long in total, and the word for the external adviser does not appear in it.

So the constraint on the provider is a single word: external. Not part of the beneficiary. The work has to be genuinely bought in.

Who can receive it — and that is where the real filter is

The restrictions in this scheme all sit on the client side, which is the practical thing to understand before anyone gets excited. To receive the aid, a company must:

• be an SME regularly established on the territory of the Grand Duchy (article 3 of the law) and incur the spend there;
• hold an autorisation d'établissement — the Luxembourg business permit issued under the modified law of 2 September 2011 governing access to the trades of craftsman, trader and industrialist and to certain liberal professions (article 1);
• not appear on the exclusion lists.

Those lists are longer than you would guess, and a few entries matter for digital projects specifically. Excluded, among others: shopping centres; retail surfaces and specialised shops with a sales area above 400 m² (furniture shops excepted); premises inside shopping centres, unless the sales area is under 400 m²; property developers, building managers and estate agents; training centres; wellness centres; security and guarding firms; taxi and chauffeur-driven car hire; transport undertakings; fuel retail; shops selling mainly tobacco or e-cigarettes.

And one entry with a certain irony: accounting firms, chartered accountants, consultants and fiduciaries are excluded as beneficiaries. A consultancy in Luxembourg cannot receive this aid. It can perfectly well be the external adviser who gets paid out of it.

Read plainly: a Belgian, Dutch, German or French agency can be the provider, but the client has to be a Luxembourg company. This is a route into a new market, not a way to put a subsidy in front of a client you already have somewhere else.

The deadline is not a date — it is an event

There is no closing date to miss, and exactly one piece of timing that will sink a file. Article 15 of the law states that the regime applies exclusively to aid having an incentive effect, and defines that effect: aid is deemed to have it if the beneficiary submitted a written application before the start of the works connected with the project.

So the sequence is fixed and there is no retroactivity in it. Scope the project, get the quote, file the application, then start. Sign the contract or begin the work first and the aid is not reduced — it is unavailable, because the legal condition for granting it can no longer be met. Nobody can fix that afterwards, however sympathetic they are.

If that sounds familiar, it is the same logic as the Brussels Prime Digitalisation, where the application must be in at the latest the day before the mission starts. Different region, different text, identical trap.

What it will not pay for

Article 5 adds two conditions that quietly rule out a lot of what agencies normally sell. The services must not constitute a permanent or periodic activity, and they must be unrelated to the undertaking's normal operating expenditure. The law then names examples of exactly that kind of expenditure: tax, financial or legal advice, or advertising.

The procedure page puts the same idea the other way round: the services must be supplied occasionally, for one-off projects. Taken together:

• A defined project with a start, an end and a deliverable — yes. A digitalisation strategy, a data audit, specifying and selecting a system, designing an e-commerce setup, an integration plan.
• A monthly retainer — no. Ongoing support, maintenance contracts and anything that renews is precisely the permanent or periodic activity the article excludes. You cannot wrap a retainer in a project title and expect it to pass.
• Advertising and campaign spend — no. It is named in the text.
• Training — not under this article. Article 5 explicitly removes costs related to training from the eligible costs.

Also worth knowing before you plan: the cumulation rules in article 17 mean you cannot stack this with another aid on the same eligible costs beyond the highest intensity applicable to them. Half the cost from two different schemes does not make a free project.

The 2026 rewrite, and the one thing it added

This is not a dusty scheme that nobody maintains. Article 5 was rewritten by the law of 22 July 2026, and the consolidated version I read is the one applicable from 15 September 2026. Three months old at the time of writing.

What the rewrite introduced is a two-track structure. SMEs keep the plain 50% with no further machinery. Large enterprises became eligible, but only inside a project falling under a cahier des charges — a set of specifications drawn up with GIE Luxinnovation, with the minister defining its modalities. That document can fix a submission deadline, the missions and deliverables expected from the external consultant, a maximum aid per enterprise, a maximum intensity, the eligible cost base, restrictions on project types by sector or technology, and the duration of the mission.

Two consequences. First, if you are an SME, none of that applies to you today and the simple reading of article 5 is the right one. Second, that mechanism now exists in the law, which is the thing to re-check before relying on this a year from now: a cahier des charges is the natural place where a requirement on the consultant could appear for the first time.

What the application file contains

Article 15 lists the minimum contents of a written application, and the list tells you how much lead time to plan for. Among the items: the name and description of the undertaking; a current legal organisation chart, dated and signed by the legal representatives, showing the structure and size of the company and its shareholding up to the beneficial owners; the closed annual accounts of the last two financial years, and those of the single economic entity it belongs to where applicable; bank details; and a description of the project including its start and end dates.

None of that is exotic, but the org chart up to beneficial owners and two years of closed accounts are not documents you assemble in an afternoon. If the project is meant to start in three weeks, the paperwork — not the scoping — is what will set the date.

Luxembourg next to Brussels

If you already know the Brussels scheme from our earlier write-ups, the comparison is the fastest way to place this one. Both let an external provider be paid; they differ in almost every other respect.

The Brussels mechanics, including the trap that closed five other primes in August 2026, are covered in Brussels Digitalisation Grant: Getting Up to €10,000 Back on a Consultancy Mission and What Brussels Cut From Its Business Primes in August 2026 — and Why Digitalisation Survived.

The structural difference is the one in the last row but one. A Brussels prime lives inside an annual budget that can be closed with five working days' notice. The Luxembourg aid has no annual filing deadline in its text at all — which makes it the calmer of the two to plan around, as long as you respect the before-the-works rule.

Where we come in

We build the digital side — websites, online shops, integrations, automation — and we are comfortable being the external adviser named in a subsidy file. On this scheme specifically, three things we would actually do:

• Tell you straight whether your project fits article 5. A one-off project with a deliverable fits. A retainer, maintenance or advertising does not, and we would rather say so at the first call than help you build a file that fails on a condition we both could have read.
• Shape the scope and the quote so the file works — a defined project with start and end dates, a deliverable that is recognisably a consultancy output, and a total that clears the minimum aid threshold instead of landing just under it.
• Sequence it correctly. Quote, application, decision, then work. We will wait for the filing before starting, because starting early is the one mistake with no remedy.

We are a Belgian agency. Under this scheme that is not a problem to work around — the law simply does not ask.

Before you build a budget around this

Treat it as a reimbursement you have a good chance of receiving if you file correctly and file before you start — never as part of your funding. Three things to re-check yourself rather than take from this page: whether a cahier des charges has been extended to SMEs, whether the scheme is still open in the form described, and the exact contents of the current application file on guichet.public.lu. The Ministry of the Economy is the only authority on its own rules, and article 5 has already been rewritten once in 2026.

If you want us to look at whether a project fits and what the file would need, write to [email protected] with your company number and a sentence about what you want to build. Every figure, article number and condition on this page was read in the consolidated law and in the grand-ducal regulation themselves on 11 October 2026.