After an initial report of unpaid overtime in the summer, the ITM has now received a new testimony denouncing working conditions at Amazon.
The accusations against the American internet giant are numerous, but they all point in the same direction: namely that it has set up an enclave of labour law in Kirchberg, where the Luxembourg Labour Code does not apply.
In August, an anonymous employee claimed he and others had not been paid a holiday supplement for hours worked on Luxembourg's National Holiday on 23 June. Now, a new report is highlighting irregularities in working hours, with employees expected to work "such reasonable hours as are necessary" above and beyond their contracted hours from 8.30am to 5.30pm.
This vague arrangement means that many exceed the legal limit of 40 hours a week, even though the law dictates a work organisation plan, reference periods, and flexible working hours.
The author of the report cites, in particular, the need to participate in online meetings with other colleagues in the United States, despite the time difference which is sometimes incompatible with a typical workday in Luxembourg. "These interactions structurally require late evening meetings to align with their time zones", he writes, adding that this expectation makes it impossible for employees to log off at 5.30pm.
The e-commerce giant's numerous sales events add an extra workload for its employees. "Secondly, during Amazon's major sales events – Prime Day, Spring Deals, Prime Big Deal Days, Black Friday – employees are routinely required to work late into the night and return early the next morning. These peak periods are predictable and recurring – they are not exceptional situations but a structural element of Amazon's annual calendar", the report continues.
Employees are not adequately compensated for these events.
“This system has real and lasting human consequences. Days that regularly extend beyond 8 or 9pm, nights shortened before an early start, weekends spent catching up on work – all this leaves little room for a normal family life, physical recovery, or maintaining a basic personal balance.”
This makes it impossible for employees to comply with the legal rest times, or the right to disconnect.
"The author [of the report] has witnessed, within his professional circle, the situations of exhaustion and the personal difficulties that these working conditions have contributed to generate. This is not a tenable situation in the long term. Every person, whatever his professional ambition, has the right to a working time that allows him to live – it is not only to work."
The person who filed the report estimated that the number of overtime hours they had accumulated during the 38 weeks preceding mid-September reached 177 hours, or roughly four and a half weeks of accumulated work beyond the legal working hours.
Furthermore, the bonus due for having worked on National Day, due to Prime Day, has still not been paid to this person.
In this context, the question arose as to whether the employees who worked that day were considered senior managers, a category that does not benefit from the overtime pay or holiday pay. The person who filed the report says that more than half of the employees (54%) are classified as "senior managers" according to an internal Amazon system. However, this classification does not meet the legal criteria required for granting this regulated status in Luxembourg.
Amazon declined to respond to RTL's questions regarding the number of employees who worked on National Day, the possible payment of the 300% increase, the existence of a system for declaring and compensating overtime, or a procedure in accordance with the law for appointing senior managers.
However, the company provided a general response that did not address any of the topics discussed above:
"Amazon is committed to creating a positive workplace and a culture of builders and innovators, where employees can develop their skills and advance their careers. Our employees can work from multiple locations, and move freely between focused work, collaboration, and breaks. In 2026, for the third consecutive year, Amazon has been recognised as a Top Employer in Luxembourg, certified by the Top Employer Institute, a global authority in HR certification. Among all Top Employers in Luxembourg, Amazon ranked first in 2025 and 2026."
The ecommerce company said that employees who volunteered to work on 23 June had been compensated in line with the law. This statement must be taken at face value until ITM completes its investigation.
