AGEFI Luxembourg - mai 2025

Mai 2025 43 AGEFI Luxembourg Informatique financière ByVincentWELLENS&OttavioCOVOLO,Avocats à la Cour, NautaDutilhAvocats Luxembourg S.à r.l. A s from2 February 2025, the first provisions under theAIAct have entered into application, more particularly, onprohibitedAI practices and the obligation to ensure a suffi- cient level ofAI literacy of the staff of user entities and other persons dealingwith the operation anduse ofAI systems, also known as “AI literacy”. The European Commissionhas recently is- sued several publications pro- viding key guidance onhow entities are to achieve it ahead of the su- pervision and enforcement rules applying from3August 2026 onwards. On 28 March 2025, the AI Office, an internal office of theEuropeanCommissionbased inBrussels and Luxembourg, has published a “Living Repository of AI Literacy Practices” containing the result of a survey conductedamong theAI Pact pledgeors (in- cluding amongst others Adobe, Booking, Capge- meni, Generali, …). (1) The results are presented as examples of practices aiming to achieveAI literacy, with the disclaimer that the practices included therein are not sanctioned or presumed to comply with theAIAct, andshouldonly serve as inspiration for other stakeholders. The main approach stemming out across the re- sponses is the reliance on mandatory (e-)learning modules tailored to the department or service into question and the circumstances in which the tool is deployed. When comparing with the practice taken within the EuropeanCommission (2) . On9April2025,theEuropeanCommissionpublished theAI ContinentAction Plan setting out key areas of focusforEUAIpolicysplitbetweentakingadvantage of research and high skill labour in the EU through appropriate financial resources, ensuring a thriving startup and scaleup scene whilst ensuring easier ac- cesstohighcomputationalresources,but,lastbutnot least,enforcingtheAIAct.Onthispoint,theEuropean Commission recognises the crucial phase that repre- sents its initial implementation and focuses its policy on streamlining compliance burdens. Concretely, anAI Act Service Desk will be launched to act as a central information hub on theAI Act “ al- lowing stakeholders to ask for help and receive tailor-made answers ”intheformof“ practicaladvice ”.TheEuropean Commission will also focus on providing “ templates, guidance, webinars and training courses to streamline pro- cedures and facilitate compliance ” and invites stakeholders to take advantageof the future regulatory sandboxes, which are estimated to be operational byApril 2026. Although these policies do respond to stakeholders’concernsandcriticismsregard- ingtheadoptionoftheAIAct,thispolicyisnot focussing on removing burdens on them, but rather helping them managing these new obligations they will need to be facing. This also highlights the thin line that the EuropeanCom- mission and other regulators are walking on when aiming to strike a balance between theiradvisoryroleinpromoting compliancepracticeswhilstreserving their possibility to effectively supervise and – if needed – take corrective measures on stakeholders which do not comply with these rules which, as stressed in the plan, were adopted to safeguard EU values of democracy and cultural diversity. This being said, the regulatory efforts undertaken by stakeholders should make use of these tools and sources made available to demonstrate their good faithwill to complywith regulatory requirements. On 7 May 2025, the European Commission pub- lishedaQ&Aon theAI literacy requirements under theAI Act. Key takeaways of this Q&A are notably thatitsscopeisnotlimitedtoemployeesofproviders and deployers, but also extends to “ persons broadly under the organisational remit ” citingas examples con- tractors, service providers and –most importantly – clients of theprovider/deployer. Thequestion, how- ever,remainsastohowsuchliteracyshouldlooklike for end-users, especially consumers and how this should be distinct from the transparency require- mentsprovidedintheAIAct.Alsointermsofscope, the Q&A confirms that staff using off-the-shelf AI tools suchasChatGPT in theirworkflowwill trigger the AI literacy obligations, implying more broadly that such use will fall within the scope of theAIAct. Stakeholders must therefore ensure that they are awareoftheAIuses,includingunsanctionedonesby theiremployees,inordertomapouttheirobligations under the AI Act, and potentially safeguard them- selves in relation to the personal data or confidential client data they are processing (especially in light of their professional secrecy obligations). The Q&A also hints at the content of the training needing tocover, amongst others, thedifferent types ofAI, the definitionof a general purposeAI (GPAI), the concrete AI use cases within the organisation, the opportunities and risks of saidAI use cases (e.g. hallucination), and any practical information that the persons may need to safely operate, deploy or otherwise interactwith theAI. The approachshould bebasedon riskandon the roleof the entityas either a provider or a deployer. TheQ&Adoes, however, clarify that theAI literacy obligation does not extend to governance require- ments, meaning that these should be read from the other provisions of theAIAct entering into applica- tionat a later date. Furthermore, testing the persons on theirAI literacy is not per se required, but itmay amount to an additional safeguard to ensure the level ofAI literacy in case of e.g. an inspectionby the relevant sectorial authority. Froman accountability standpoint, internal records of attendance are deemed sufficient. 1) The AI Pact is a voluntary programme of information ex- change and training between stakeholders and the European Commission. 2)The DevelopapolicytobuildandmaintainanAI-skilledworkforce developed by theAI@ECCommunication team. “Beware of AI”: clarifications given onAI literacy requirements Why data, customisation, and distribu- tionmattermore than ever ByOrianeKAESMANN,ResearchManager the LHoFT I n today’s investment land- scape, client reporting has evolved froma routine task to a pivotal element of client engage- ment and satisfaction. More than ever, investors demand timely, customised insights delivered through their preferred channels, reflecting a broader trend towards personalised financial services. This shift presents a significant challenge for asset managers, who must navigate complex data envi- ronments and heightened expecta- tions without overburdening their operational capacities. A study by Alpha FMC (1) highlights that clientreportingremainsahighlycomplex and labour-intensive process across the asset management industry. The study emphasises the need for firms to assess their client reporting operatingmodels to simplify, standardise, and maximise the benefitsfromvendorcapabilities,embed- ded alongside in-house expertise. In response to these challenges, the need to leverage automation to deliver tailored client communications efficiently - and transforming reporting from a cumber- some obligation into a strategic asset has become essential. Section I: ReportingRedesign In the evolving landscape of investment management, client reporting has transi- tionedfromaroutineoperationaltasktoa strategicimperative.Clientsnowdemand timely,personalised,andaccessiblereport- ing,challengingfirmstoadapttheirlegacy systems andprocesses accordingly. Alpha FMC’s 2023 Asset Management DigitalReadinessSurvey (2) ,encompassing insights from 50 leading asset managers overseeing a combined $34 trillion in assets, highlights this shift. The survey reveals that while 92% of firms prioritise digitisation, progress in digital maturity remains sluggish, hindered by organisa- tional challenges, data accessibility issues, and constrainedbudgets. Notably, firms are increasingly investing in digital client servicing, with 26% of digital transformation budgets allocated to this domain. This focus underscores the industry’s recognition of the need to enhance client experiences through improved reporting capabilities. However, many firms struggle with the “last mile” of data delivery: translating internal data into client-facing insights. Organisational structures and legacysys- tems (3) often impede the seamless inte- gration of data into client reports, result- ing in inefficiencies and suboptimal client experiences. To bridge this gap, asset managers are exploringautomationandadvancedana- lyticstostreamlinereportingprocesses.By leveragingtechnology,firmsaimtodeliv- er customised, timely, and accurate reports, thereby enhancing client satisfac- tion andoperational efficiency. Section II: Inside theKurtosysModel As investment firms continuenavigating a fast-changing landscape marked by digitisation, heightened client expecta- tions, and increasingly complex report- ing requirements, many are being pushed to reassess how they approach investor servicing. A recent study con- ducted byKurtosys, in partnershipwith AdoxResearch, sheds light onhowfirms are responding—and where the biggest challenges still lie. The survey, The Client Reporting Playbook: Analysing the Latest Trends in Investor ServicingandReporting (4) ,gatheredinsights from 65 investment managers across the industry. It revealed a growing focus on deliveringpersonalised,scalable,andflex- ible reporting experiences. But progress is uneven—and data quality is still a majorstumblingblock.Nearlyfourinfive respondents (78%) reported recurring issueswithdata quality, andmore than a third (37%) said they regularly receive dataoutsideofagreedservicelevelagree- ments (SLAs). Thislackofreliabledatahasdownstream effects. Just 8% of investment managers said they can produce fully customised clientreportswithoutadditionalsupport. Formany,reportgenerationstilldepends heavily on IT involvement, whether for database calculations, configuring tem- plates, or managing backend systems. The result is a process that’s often too manual and too time-consuming to be viable, not tomention the vulnerabilities to compliance risks. The path forward begins, unsurprisingly, with the data itself.Morethan20%ofrespondentshave already adoptedmodern data platforms suchasSnowflakeandDatabrickstohelp centralise, validate, and query their reporting data. These tools are helping firms automatekeypartsof the reporting process, reducing the need for manual intervention and allowing teams to respond to client needsmore efficiently. But having clean, accessible data is only partofthesolution.Investmentmanagers alsoneed tools thatmake it easier tobuild and deliver tailored client experiences. Integratingreportingprocesseswithfamil- iar tools like Microsoft Excel, Word, PowerPoint, andAdobe InDesign allows teamstocreateandshareaccurate,engag- ingandinteractivedatavisualisationsand consistent reports in a timely manner— withoutsacrificingcomplianceorscalabil- ity.Delivery,too,playsacriticalrole.While some clients prefer accessing reports via a secureportal,othersfavourreceivingthem by email. The survey found preferences split evenly—43% in each camp—under- scoringtheneedforaflexible,multi-chan- neldistributionapproach.Firmsthatlimit themselves to a single delivery method risk falling short of client expectations. Section III: Business Value on a Silver Platter Digital client reporting platforms have evolved well beyond operational sup- port tools; they are now pivotal to com- petitive positioning, client satisfaction and regulatory assurance. Byautomating complex reportingwork- flows, firms can drastically reduce error rates and accelerate delivery cycles. This shift eliminates themanual burdenoften associatedwith spreadsheet-heavy pro- cesses, allowing reporting teams to focus on value-added tasks rather than for- matting inconsistencies. By standardis- ing data flows and formatting rules, firms can eliminate the risks inherent in manual reporting processes. The result is a consistent, audit-ready output deliv- ered in hours, not days. Additionally, tailored, timely, and visu- ally coherent reporting deepens trust with institutional and retail clients alike. Investors now expect reporting that is not only accurate but aligned with their investment strategy, objectives, andpre- ferred delivery formats. Meeting these expectations helps solidify relationships and improve client retention. In term of regulatory assurance, those platforms embed compliance checks, audit trails, and rule-based governance within the reporting lifecycle. This not only reduces the likelihoodof regulatorybreaches but also equips firms to respond rapidly to evolving disclosure standards across jurisdictions. Modern solutions are designed with adaptability in mind, often integrating AI-generated commentary, enabling multilingual outputs, or supporting dynamic and interactive reporting. A compelling example comes froma glob- al assetmanagement firmthat leveraged AI-powered natural language genera- tion to automate thousands of fundper- formance commentaries (5) . This type of implementation helps reduce turnaround time from days to minutes and ensured consistency across reports, all while improving client engagement at scale. Conclusion Client reporting is no longer a backstage function; it’s a headline act. As expecta- tions evolve, the asset management industry must pivot from patchwork solutions topurpose-built platforms that treat data not as a burdenbut as a source of strategic advantage. What’s clear is this: the future belongs to firms that can seamlessly transform raw data into personalised, compliant, andvisually engaging reports delivered through the client’s channel of choice. Platforms like Kurtosys are redefining this paradigm, offering technology that anticipates needs, removes friction, and elevates service fromadequate to excep- tional. In 2025 and beyond, the winners won’t just be those who report well; they’ll be those who communicate with clarity, agility, and empathy. And in doing so, they’ll build the trust that fuels long-term success. Kurtosys helps investment managers streamline the deliveryofdataandinsightstoinvestors.Theirplatform brings together reporting, client portals, and fund web- sites to enhance efficiency, accuracy, and the overall investor experience – built for today and ready for the future. Find out more about their solutions by visiting www.kurtosys.com. Readthe fullreporthere :https://bit.ly/3GHCLZu 1)TomGoldwater,ChyavanRees,AlexSabato(12 May 2023) “Client Reporting Challenges in Asset Management – A Client Service Differentiator, or anInconvenientNecessity? ”https://urls.fr/hl7c75 2)KevinO’Shaughnessy,MarkWebb(28July2023) “AssetManagement Digital Survey 2023:ATale of TwoCities” ,https://urls.fr/Q00Z1u 3) AlphaMC, “What are the key drivers for change in Wealth Managers right now?” https://urls.fr/zr7aqt 4) Kurtosys (February 2025) “Unlock exclusive insights: The client reporting playbook” https://urlr.me/KdESpu 5) Amy McCloskey Tobin (December 18, 2023) “How a Global Asset Management Firm Uses AI toAutomateClientReporting” https://urlr.me/dgshuJ LHoFT Research Client Reporting in 2025 ©Midjourney