Psychotherapists in Luxembourg: patient records, secrecy and CNS reimbursement

In Luxembourg, a psychotherapist is a health professional who practises under an authorisation from the Minister of Health (law of 14 July 2015). They keep a record for each patient for at least ten years after care ends, they are bound by the secrecy rule of Article 458 of the Criminal Code, and their sessions have been reimbursed by the CNS since 1 February 2023, on a medical prescription.

Who can practise and bill sessions to the CNS

Article 2 of the law of 14 July 2015 creating the profession of psychotherapist sets the rule (our translation): practising as a psychotherapist requires an authorisation from the minister responsible for Health. The title is protected (Article 3). In practice:

• Degrees: a master's in clinical psychology (or equivalent) or basic medical training, plus a psychotherapy qualification.
• Application: on MyGuichet.lu (€75), with an opinion from the Collège médical within 3 weeks to 3 months, according to Guichet.lu.
• Professional liability insurance: mandatory, on pain of disciplinary sanctions (Article 2(3)).
• Registers: registration with the ministry's professional register and the Collège médical register within one month of setting up (Article 7).
• CNS provider code: the government asked psychotherapists to apply for one, as it is needed to deliver acts covered by health insurance (government press release, January 2023).

The patient record: what the 2014 law says

The law of 24 July 2014 on patients’ rights and obligations applies to every health professional, including authorised psychotherapists. Article 15(1), in our translation:

"The patient is entitled, from the healthcare provider, to a carefully updated patient record. The patient record traces, chronologically and faithfully, the patient's state of health and its evolution during care. It contains all information relevant to the safety and the evolution of the patient's state of health."

The minimum content is to be set by Grand-Ducal regulation. As of 5 November 2026 we found none for psychotherapists. The law already sets two precise rules:

• Identification and date: for each service, the professional who provided it is identified, and the date (and, where relevant, the time) must be stated (Article 15(2)).
• Corrections: correcting an inaccurate entry "must be reversible and documented" (Article 15(5)).

How long to keep the record

Article 15(4) (our translation): "The custodian of a patient record must keep it for at least ten years from the date care ended." We advise noting an explicit end date in every record.

French rules differ; see our French page on how long to keep patient records in France.

Patient access and personal notes

• Copy: on paper or in electronic form, as the patient chooses. Charges may not exceed the cost of reproduction and, where relevant, postage (Article 16(3)).
• Time limit: within 15 working days at most from receipt of the request, unless the patient's health requires faster access (Article 16(4)).
• Personal notes: Article 17(2). Personal notes and data supplied by third parties may be withheld from the patient, provided they concern neither care nor continuity of care. Personal data about third parties is never disclosed.

In our reading, a clinical hypothesis that guides treatment concerns care, so it does not belong in personal notes. We advise keeping the two apart from the moment you write.

Patient record template to copy

1. Identification

• Patient's name and date of birth
• 13-digit identification number (for fee notes)
• For a minor: legal representatives, and any decision to let them exercise their rights alone (Article 13)

2. Prescription and CNS cover

• Prescribing doctor, prescription date, exact number of sessions prescribed
• Date of the first SP01 session (to check the 90-day limit)
• Counter: SP01 x / 3, SP02 x / 24, SP03 x / 24 for the current prescription

3. Referral and initial assessment

• Reason for consulting, history of the difficulty, current treatment reported
• Working hypotheses, agreed goals, consent to care (date)

4. Note for each session

• Date, start time, length (50 to 60 minutes for a CNS act), act code
• Name of the psychotherapist who held the session
• Themes, interventions, patient's response
• Progress against goals
• Points to pick up next session

5. Correspondence and documents

• Letters sent or received (doctor, other professionals), with the patient's agreement noted
• Access or copy requests: date received, date answered

6. Closing

• Date care ended
• Summary of the therapy and any referral

7. Personal notes (separate section)

• Reflections, impressions, thoughts with no bearing on care (Article 17)

For writing the notes themselves, see our French session notes template.

Professional secrecy for psychotherapists

Article 8 of the 2015 law is short (our translation): people practising as psychotherapists and students in training are bound by professional secrecy under the conditions and reservations of Article 458 of the Criminal Code.

Article 458 of the Criminal Code punishes doctors, pharmacists, midwives "and all other persons who, by status or profession, are entrusted with secrets" (our translation) who reveal them, outside testimony in court and cases where the law requires disclosure. The penalty is eight days to six months in prison and a fine of €500 to €5,000.

The 2014 law provides for controlled exceptions, notably towards the companion chosen by the patient (Article 7), the trusted person (Article 12) and other health professionals, unless the duly informed patient objects (Article 18).

The 2015 law also asks the Collège médical to adopt a regulation on ethics and professional secrecy (Article 7). We advise checking the text in force with the Collège médical.

A software tool that processes your notes is a processor under the GDPR. The CNPD asks you to check that your processors know their obligations and responsibilities. For choosing an AI assistant, see our French guide on AI assistants, GDPR and Europe and our page on the EU AI Act for psychologists.

CNS reimbursement step by step

In late 2022, the CNS and the psychotherapists' federation (FAPSYLUX) did not reach a fee agreement. The government described it as a "non-conciliation" (press release of 16 December 2022), and the value of the key letter was set by Grand-Ducal regulation, on a proposal from the Minister of Social Security. We found no signed agreement since.

The CNS fee schedule in force on 1 June 2026 lists three acts at €162.92 each.

SP01 initiation session, SP02 supportive session, SP03 extended supportive session. A session lasts 50 to 60 minutes, and only one act may be billed per day.

The steps

• 1. Initiation: the patient may have one to three SP01 sessions without a prior prescription. A prescription must then be issued within 90 days of the first session.
• 2. Prescription: the doctor certifies there is no medical contraindication, that the disorder has no somatic cause, where relevant that psychotherapy is appropriate, and the exact number of sessions prescribed. The CNS publishes a prescription form, "Ordonnance médicale - Psychothérapie" (whether it is mandatory is not stated).
• 3. Support: for SP02 and SP03, the prescription must exist before the session. Treatment starts within 90 days of the prescription unless the doctor says otherwise. The first prescription covers at most 27 sessions (3 SP01 and 24 SP02).
• 4. Extended support: a new prescription for each series of 24 SP03 sessions.
• 5. Limits: every 5 years, 3 SP01 and 24 SP02. Every 10 years, 120 SP03. The periods start from the date the prescription was issued. For SP01, the CNS example starts the period 90 days before that date.
• 6. Fee note: the patient pays. You hand over a receipted fee note with the insured person's name, first name and 13-digit identification number, showing the covered and uncovered amounts.
• 7. Claim: the patient sends the fee notes to the CNS (or the public sector fund), with the original prescription enclosed with the first claim.

What changes the amount or blocks reimbursement

• Rate: 70% for adults, 100% for insured persons under 18 on the prescription date.
• Teleconsultation: not covered, in Luxembourg or abroad, according to the CNS.
• Abroad: same terms with a psychotherapist established in the EU, Norway, Iceland, Liechtenstein or Switzerland. A cross-border worker consulting in their country of residence claims from that country's fund.
• High out-of-pocket costs: psychotherapy is among the services eligible for the CNS complementary payment, above 2.5% of the previous year's contributory income.

Do you need to report to the prescribing doctor

No official text we read (2015 law, fee schedule, CNS psychotherapy page) requires this report. But the doctor will often write the next prescription. Article 18 of the 2014 law allows health professionals to share information for continuity of care, unless the duly informed patient objects. We advise a short letter, reviewed with the patient, and a note of their agreement in the record.

Letter template for the prescribing doctor

Dear Dr [Name],

On [date] you prescribed [number] psychotherapy sessions for [First name Surname], born on [date]. With their agreement, here is an update on the therapy.

• Sessions held: [x] SP01 and [x] SP02 between [date] and [date].
• Initial request: [one sentence, in terms agreed with the patient].
• Progress: [goals met, in progress, difficulties].
• Proposed next steps: [continue with 24 SP03 sessions, spacing, ending therapy].

I am happy to discuss this. Kind regards,

[Name], authorised psychotherapist, [address, phone]

More letter and report templates are in our clinical document templates.

A complete fictional example

Fictional example, invented names. Claire is an authorised psychotherapist in Esch-sur-Alzette. Marc, 34, insured with the CNS, contacts her without a prescription.

• 7 September 2026: first SP01 session (55 minutes). Claire opens the record and notes Marc's 13-digit number and the date of the first SP01. Marc pays €162.92 and receives a receipted fee note.
• 18 September 2026: his GP issues a prescription for 27 sessions, on the CNS form.
• 28 September 2026: first SP02. Counter: SP01 3/3, SP02 1/24.
• October 2026: Marc sends his first four fee notes and the original prescription to the CNS. Expected reimbursement: €114.04 per session (70%). His share: €48.88 per session.
• March 2027: with Marc's agreement noted in the record, Claire sends a written update to his doctor.
• End of 2027: care closes on 15 December 2027. The record will be kept at least until 15 December 2037.

Checklist

• For each patient: 13-digit number, date of first SP01, date and number of sessions on the prescription.
• Sessions of 50 to 60 minutes, one act per day, no video session billed as a CNS act.
• Receipted fee notes with name, first name, identification number, covered and patient amounts.
• Every note dated, with your name. Corrections reversible and documented.
• A process to answer access requests within 15 working days at most.
• End-of-care date noted, ten-year period calculated.

Common mistakes

• A prescription without a number of sessions: the CNS requires the exact number of sessions prescribed.
• Forgetting the new prescription for each series of 24 SP03.
• Using an old fee: €144 set in late 2022, €158.95 on 1 May 2025, €162.92 since 1 June 2026.
• Putting clinical hypotheses in personal notes to keep them from the patient.

Why Delta fits this case

Delta is the clinical assistant that keeps the memory of every patient. During the session it transcribes what is said; afterwards you can dictate your observations. It produces a dated report for each session, updates the patient record (summary of the therapy, goals followed) and drafts your letters to doctors in your own vocabulary. Data stays in Europe, in France, on infrastructure certified for health data. The patient's name and identifying details are pseudonymised before the AI, no audio file is kept, and data is never used to train a model. Delta does not handle billing or CNS fee notes.

Sources

• Law of 24 July 2014 on patients' rights and obligations, Mémorial A140 (Legilux, in French)
• Law of 14 July 2015 creating the profession of psychotherapist, Mémorial A136 (Legilux, in French)
• Criminal Code, Article 458 (Legilux, consolidated version read on 5 November 2026, in French)
• CNS, Psychotherapy, page updated 5 March 2026
• CNS, psychotherapists' fee schedule, version of 1 June 2026 (in French)