# LNDS explained: Luxembourg's National Data Service, public data reuse and the health data space

> LNDS helps Luxembourg public bodies make protected data reusable for research and innovation; first requests under the law of 19 December 2025 are due in 2026.

Published: 2026-09-26 · Dataplaz editorial team · https://dataplaz.lu/en/lnds-luxembourg-national-data-service/

## Key takeaways
- The Luxembourg National Data Service (LNDS) is the brand of PNED G.I.E., an economic interest group created by the government in July 2022 and based in Esch-sur-Alzette.
- LNDS services, from project onboarding to secure processing environments, are free of charge for public bodies, companies and researchers.
- The law of 19 December 2025, published in Mémorial A n°619, implements the Data Governance Act and makes the Commissariat du Gouvernement à la souveraineté des données the body that grants or refuses reuse of protected public data.
- LNDS coordinates HDAB-LU, an EU4Health project started in January 2024 to prepare Luxembourg's future Health Data Access Body under the European Health Data Space regulation.
- Under Regulation (EU) 2025/327, health data access bodies must be designated by 26 March 2027 and secondary-use rules apply to most data categories from March 2029.

The Luxembourg National Data Service (LNDS) is the state-owned service, created in July 2022, that helps public bodies make their data reusable for research, innovation and public policy, free of charge for its users. With the law of 19 December 2025 implementing the EU Data Governance Act, the first formal requests to reuse protected public data in Luxembourg are expected in 2026: a new government commissariat decides on access, while LNDS supports the preparation of the data. LNDS also builds the technical groundwork for Luxembourg's future Health Data Access Body under the European Health Data Space.

## What LNDS is

LNDS is the brand of PNED G.I.E., an economic interest group fully owned by the Luxembourg government and based in Esch-sur-Alzette. According to [LNDS](https://www.lnds.lu/about-us/), its board includes representatives of the ministries in charge of research, digitalisation, the economy, finance, health and the State, as well as the Luxembourg Institute of Health and the Luxembourg Institute of Socio-Economic Research. Its chief executive is Bert Verdonck.

Its mission is to enable value creation from the secondary use of data, meaning the reuse of data collected for one purpose, such as administration or care, for another, such as research or statistics, with transparency, control and trust.

## What LNDS does

[LNDS lists](https://www.lnds.lu/services/) more than fifteen services, including:

- data project consulting and onboarding;
- data access request and review;
- data cataloguing, data quality and curation;
- data extraction, enrichment and merging from several sources;
- pseudonymisation and synthetic data generation;
- a secure processing environment for confidential data;
- legal, ethical and societal (ELSI) expertise and data protection training.

The services are free of charge and open to public organisations, private companies and EU researchers. According to [Delano](https://delano.lu/article/lnds-prepares-first-public-data-access), LNDS had completed 56 projects, with 11 more under way at the end of 2025, in areas such as health, transport, environment, energy and official statistics. LNDS is also a partner of the Luxembourg AI Factory.

## The Data Governance Act context

The Data Governance Act, Regulation (EU) 2022/868, entered into force on 23 June 2022 and has applied since September 2023, according to the [European Commission](https://digital-strategy.ec.europa.eu/en/policies/data-governance-act). Among other things, it sets rules for reusing public sector data that cannot be released as open data because it is personal, confidential or protected.

Luxembourg implemented the institutional part through bill n°8395A. The Chambre des Députés adopted it unanimously on 18 December 2025, and it became the law of 19 December 2025, published in Mémorial A n°619 ([dossier 8395A](https://www.chd.lu/en/dossier/8395A)). It allocates the roles as follows:

| Role under the Data Governance Act | Body in Luxembourg |
|---|---|
| Competent body that grants or refuses reuse (Art. 7) | Commissariat du Gouvernement à la souveraineté des données, via its Autorité luxembourgeoise des données |
| Single information point (Art. 8) | Minister responsible for Digitalisation |
| Data intermediation services (Art. 13) | Commission nationale pour la protection des données (CNPD) |
| Register of data altruism organisations (Art. 23) | CNPD |

The Commissariat replaces the former Commissariat du Gouvernement à la protection des données auprès de l'État. Under [the voted text](https://wdocs-pub.chd.lu/docs/Dossiers_parlementaires/8395A/20251218_TexteVote.pdf), it may authorise reuse only with the agreement of the public body holding the data and only when:

- the purpose is statistical analysis, education or training, scientific research, historical research, or the evaluation of Luxembourg or European public policies;
- the data has been anonymised, pseudonymised or otherwise protected against disclosure;
- the data is accessed in a secure processing environment provided by the Commissariat;
- there is no risk to national defence, public security or public order.

The data holder has three weeks to decide; no decision within that period counts as a refusal. The Commissariat can impose fines of EUR 500 to 100,000 on reusers who breach their obligations and exclude them from new requests for up to two years. Its decisions can be appealed before the Tribunal administratif.

On LNDS's own position, the sources do not fully align. LNDS describes itself as providing services as a competent body under the Data Governance Act, while the law designates the Commissariat as the deciding body. Delano reports that LNDS will support the first access requests in 2026, mainly by cataloguing, improving and anonymising data. As of the latest information available on 6 October 2026, the detailed operational split between LNDS and the Commissariat had not been published.

A second part of the original bill, n°8395B on the "once only" principle and GDPR provisions, was still in committee, with the latest Conseil d'État opinion dated 10 July 2026 ([dossier 8395B](https://www.chd.lu/en/dossier/8395B)).

## The link to the European Health Data Space

The European Health Data Space regulation, Regulation (EU) 2025/327, entered into force on 26 March 2025. According to the [European Commission](https://health.ec.europa.eu/ehealth-digital-health-and-care/european-health-data-space-regulation-ehds_en), its secondary-use rules apply from March 2029 for most data categories, such as electronic health records, and from March 2031 for the rest, including genomic data. Under Article 55(6), Member States must designate one or more Health Data Access Bodies (HDABs) and inform the Commission of them by 26 March 2027.

LNDS coordinates [HDAB-LU](https://www.lnds.lu/hdab-lu/), a four-year project funded by the EU4Health programme that started in January 2024. The Ministry of Health and Social Security nominated LNDS to apply for the grant. The project builds four components: a national data access application system, a national health dataset catalogue, secure processing environments and a cross-border gateway to the EU infrastructure. LNDS stresses that HDAB-LU is preparatory and does not assign the HDAB role; the body will be designated by future Luxembourg legislation implementing the EHDS.

On 31 October 2025 [LNDS reported](https://www.lnds.lu/shaping-the-future-of-health-data-in-europe-lnds-contribution/) that Luxembourg and the Netherlands were the first two countries with operational EHDS cross-border gateways, and that it contributes to the TEHDAS2 joint action on HDAB guidelines.

## How researchers and companies request access

| Situation | Route as of October 2026 |
|---|---|
| Project needing help to find, prepare or combine public data | LNDS onboarding form or service desk at service.desk.lnds.lu |
| Reuse of protected public sector data under the Data Governance Act | Request decided by the Commissariat du Gouvernement à la souveraineté des données, with the data holder's agreement, in a secure processing environment |
| Secondary use of health data under the EHDS | No EHDS route yet; the HDAB still has to be designated |

At the Data Summit Luxembourg on 2 December 2025, according to Delano, a single information point for public data requests and a "Luxembourg Data Factory" for preparing public data were announced. Their launch dates had not been published as of 6 October 2026.

## What to do now

1. Check whether the data needed is already open data before planning a protected-data request.
2. Describe the purpose precisely and confirm it falls under one of the purposes listed in the law of 19 December 2025.
3. Contact LNDS through its onboarding form or service desk for an initial consultation on data availability and preparation.
4. Plan for work inside a secure processing environment, with anonymised or pseudonymised data only.
5. Health research teams should follow the designation of Luxembourg's HDAB, due by March 2027, and the EHDS timetable to 2029.

## Questions & answers
**What is the Luxembourg National Data Service?**
LNDS is a government-owned economic interest group (PNED G.I.E.) founded in July 2022. It helps public bodies prepare their data for secure secondary use by researchers, public organisations and companies.

**Are LNDS services free?**
Yes. LNDS states that its services are free of charge. They are open to public organisations, private companies and EU researchers.

**Who decides on access to protected public data in Luxembourg?**
Under the law of 19 December 2025, the Commissariat du Gouvernement à la souveraineté des données, through its Luxembourg Data Authority, grants or refuses access, after the public body holding the data has agreed.

**Is LNDS Luxembourg's Health Data Access Body?**
Not formally. LNDS coordinates the HDAB-LU preparatory project, but states that this is not the assignment of the HDAB role; the body will be designated by future Luxembourg legislation implementing the EHDS.

**When can health data be requested under the European Health Data Space?**
Secondary-use rules apply from March 2029 for most data categories, such as electronic health records, and from March 2031 for the remaining categories, including genomic data.

**Can private companies use LNDS?**
Yes. LNDS lists private companies among the users of its services; access to protected public data still requires authorisation for one of the purposes defined by law.

## Sources
1. [About us](https://www.lnds.lu/about-us/) · LNDS
2. [LNDS services](https://www.lnds.lu/services/) · LNDS
3. [Project HDAB-LU](https://www.lnds.lu/hdab-lu/) · LNDS
4. [Shaping the future of health data in Europe: how LNDS contributes to the European Health Data Space (31 October 2025)](https://www.lnds.lu/shaping-the-future-of-health-data-in-europe-lnds-contribution/) · LNDS
5. [Dossier parlementaire 8395A (law of 19 December 2025 creating the Commissariat du Gouvernement à la souveraineté des données)](https://www.chd.lu/en/dossier/8395A) · Chambre des Députés
6. [Texte voté, projet de loi n°8395A (18 December 2025)](https://wdocs-pub.chd.lu/docs/Dossiers_parlementaires/8395A/20251218_TexteVote.pdf) · Chambre des Députés
7. [Dossier parlementaire 8395B (once-only principle)](https://www.chd.lu/en/dossier/8395B) · Chambre des Députés
8. [Data Governance Act](https://digital-strategy.ec.europa.eu/en/policies/data-governance-act) · European Commission
9. [European Health Data Space Regulation (EHDS)](https://health.ec.europa.eu/ehealth-digital-health-and-care/european-health-data-space-regulation-ehds_en) · European Commission
10. [Regulation (EU) 2025/327 (EHDS), Article 55](https://streamlex.eu/articles/ehds-en-art-55/) · Streamlex
11. [LNDS prepares first public data access](https://delano.lu/article/lnds-prepares-first-public-data-access) · Delano