Undocumented migrant count impossible, Luxembourg says
Aug 26, 2026
Category: Luxembourg Migration News
The Luxembourg government said that there is no reliable way to count undocumented migrants living in the country because, by definition, they are not registered with the authorities.
The position was set out in a written reply to a parliamentary question from Luxembourg Socialist Workers’ Party (LSAP) MP Mars Di Bartolomeo.
Officials argued that people who avoid the authorities do not appear in administrative records, making a reliable national estimate impossible.
Counting the uncountable
Even the Directorate of Immigration only records people who enter official procedures. Those who avoid contact with the authorities remain outside the system.
The government also rejects visual impressions or informal estimates as unreliable and potentially discriminatory, particularly in a diverse country such as Luxembourg.
There is no research to fill the gap either. No dedicated study on irregular migration in Luxembourg has been commissioned.
Inspectors catch 106 at work
Workplace inspections provide one of the few concrete indicators, although the government considers the figures incomplete.
The Labour and Mines Inspectorate (Inspection du travail et des mines, ITM) conducted more than 17,000 workplace inspections in 2025, including over 8,300 at construction sites and 2,760 in manufacturing.
Inspectors found 106 foreign nationals in an irregular situation, including 69 working in hotels, restaurants and cafés.
Hospitality has consistently accounted for a large share of detected irregular employment. Between 2021 and 2025, it represented more than half of all irregular workers identified by ITM.
Violations included missing employment contracts, absent social security registration, excessive working hours and unpaid wages.
No papers at school gate
The government applies a similar principle to schools. Pupils cannot be identified according to their parents’ residency status.
It stressed that no child can be denied education because of their family’s administrative situation. Policies are therefore designed to prevent distinctions or stigmatisation based on residency status.
Guarding gate, not house
Two EU systems could improve monitoring at external borders without solving Luxembourg’s central problem.
The Entry/Exit System (EES) records non-EU nationals entering and leaving the Schengen area, helping authorities identify travellers who overstay permitted short visits.
The European Travel Information and Authorisation System (ETIAS), which is not yet operational, will screen visa-exempt travellers before departure.
Neither system, however, can account for people already living in Luxembourg without registration, those who entered before the systems were introduced or those who avoided detection entirely.
The technology sharpens the picture at the border, not inside the country.
The number nobody can give
Luxembourg’s reply distinguishes between what authorities can measure and what remains invisible.
Figures such as the 106 irregular workers identified in 2025 are based on direct contact with officials. People who avoid those encounters cannot be reliably counted, which is why the government refuses to produce a national estimate.
For employers, particularly in construction and hospitality, the figures also show where inspections are concentrated. For undocumented families, the education guarantee places schooling outside residency-based discrimination.
EU border systems may improve entry and exit data, but they will not provide the internal count sought by the parliamentary question.
Questions remain over whether Luxembourg will eventually commission a dedicated study, whether irregular employment will remain concentrated in hospitality and how EES and ETIAS data may influence enforcement.
For now, the official answer remains unchanged: Luxembourg does not know how many undocumented migrants live in the country, and the government says there is no responsible way to calculate the figure.