UEL recommendations on the CovidCheck regime


The modalities of the CovidCheck regime as envisaged in this law have been the subject of debate and reflection in the press in recent days. However, they remain unclear at this stage, given the criticisms made by various stakeholders in the current legislative process.

Although the employers’ organisations welcome the optional introduction of the CovidCheck in companies, outside the horeca sector, according to article 6 of the law project, it would however be premature to introduce a CovidCheck regime on this basis without waiting for the vote of the law which should intervene at the latest on 18 October.

UEL and its members therefore recommend that companies avoid taking any initiatives on the level of the CovidCheck regime which risk being deprived of a legal basis following the next version of the law on the measures to combat the Covid-19 pandemic. However, companies can now announce their willingness to join such a scheme and start preparing the organisation to facilitate and accelerate its implementation while respecting the competences of the staff delegation once the law is adopted.

UEL recalls in this context the importance of respecting the data protection requirements of the RGPD in this very sensitive area of health data.

Note from the UEL
Luxembourg, 15 October 2021