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Second thematic review on the use of Artificial Intelligence in the Luxembourg Financial sector

16.05.2025

The Banque centrale du Luxembourg (BCL) and the Commission de Surveillance du Secteur Financier (CSSF) published today the second thematic report on the use of Artificial Intelligence (AI) in Luxembourg’s financial sector.

Building on a similar study conducted in 2023[1], this report examines the evolving adoption of AI within the sector, with a particular focus on the growing prevalence and associated risks of Generative AI (GenAI). The report presents the findings of a survey conducted between June and August 2024, encompassing Investment Firms (IFs), Authorised Investment Fund Managers (IFMs/AIFMs)[2], Credit Institutions (B), E-money Institutions (EMIs), and Payment Institutions (PIs). This expanded scope represents more than a threefold increase in participation compared to the previous survey, which focused solely on Credit Institutions, E-money Institutions and Payment Institutions.

The report provides detailed analysis of digital strategies, investments in innovative technologies, and the organisational and technical setup supporting AI adoption. It highlights reported AI use cases, with a comparative overview of GenAI and Machine Learning (ML) applications. Furthermore, the report assesses key trustworthiness aspects of AI implementation, including bias management, explainability, auditability, and human oversight. Notably, the report includes an initial analysis of the risk classification of the use cases according to the EU AI Act, identifying areas requiring further consideration.

With a strong response rate of 86% from 461 financial institutions, the findings are representative of the Luxembourg financial sector. The BCL and CSSF believe this report will serve as a valuable resource for fostering both innovation and the trustworthy application of AI within the sector.

The present joint Thematic report on Artificial Intelligence reproduces a summary of the main findings from the survey.

  

[1] See https://www.bcl.lu/en/Media-and-News/Press-releases/2023/05/ai/index.html.

[2] More specifically, the following types of fund managers were in scope of the survey: management companies subject to Chapter 15 (CH15 ManCo) of the Law of 17 December 2010 relating to undertakings for collective investment (2010 Law); authorised alternative investment fund managers (AIFMs) subject to the Law of 12 July 2013 on alternative investment fund managers (2013 Law).