Luxembourg - Tier B · Contained · Question to the Commissariat aux Assurances
Posted: Sun Oct 11, 2026 8:44 am
Fijishi Jurisdiction Index 2026 · Entry LU · Published 12 October 2026
At a glance
1. The rules in Luxembourg
The EU AI Act's duty to tell people they are interacting with an AI system (Article 50(1)) has applied since 2 August 2026, and is mainly enforced by national market surveillance authorities.
Luxembourg's bill 8476, filed on 23 December 2024, would designate the Commissariat aux Assurances as market surveillance authority for AI systems used by entities it supervises. The bill was in committee when last observed, with no step recorded after 10 July 2026.
Who these rules reach
This band describes how far the published record answers the question put to the Commissariat aux Assurances. It is not a finding that the Commissariat aux Assurances, or any firm it oversees, has fallen short of any rule.
Why the question goes to the Commissariat aux Assurances: The question concerns the supervisor's own competence, and this entry relies on no single company's account.
The question
3. What the open question means for firms in Luxembourg
Until the Commissariat answers, an insurer in Luxembourg running a customer-facing AI system has no published statement on whether any Luxembourg authority can check its Article 50(1) duty before the bill is passed. This entry gives no band to any firm.
4. What this entry does not establish
Sources
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Commercial relationship with any party named here: None · Right of reply: indexreport.protocol@fijishi.com; with the sender's agreement, replies are published in full below the entry, dated · Cite as: Fijishi Jurisdiction Index 2026, Entry LU · Corrections: none.
At a glance
| Jurisdiction tier | Tier B - Specified; enforcement stated, not yet live. AI is specified as for Tier A, and a mechanism to check or sanction it has been stated but is not yet shown to be live. |
| Question to | the Commissariat aux Assurances - enforcement of the AI Act's transparency duty |
| Band for this question | Contained |
| Rules reach | Insurers: directly · Reinsurers: directly · Intermediaries: directly |
| Last verified | [actual date of the launch-window check] |
The EU AI Act's duty to tell people they are interacting with an AI system (Article 50(1)) has applied since 2 August 2026, and is mainly enforced by national market surveillance authorities.
Luxembourg's bill 8476, filed on 23 December 2024, would designate the Commissariat aux Assurances as market surveillance authority for AI systems used by entities it supervises. The bill was in committee when last observed, with no step recorded after 10 July 2026.
Who these rules reach
- Insurers: directly, where the insurer is the provider. Article 50(1): "Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system". Read on a secondary host.
- Reinsurers: directly, where the reinsurer is the provider, under the same words.
- Intermediaries: directly, where the intermediary is the provider, under the same words.
This band describes how far the published record answers the question put to the Commissariat aux Assurances. It is not a finding that the Commissariat aux Assurances, or any firm it oversees, has fallen short of any rule.
Why the question goes to the Commissariat aux Assurances: The question concerns the supervisor's own competence, and this entry relies on no single company's account.
The question
In briefThe EU AI Act's duty to tell people they are interacting with an AI system (Article 50(1)) has applied since 2 August 2026, and the European Commission says compliance will mainly be enforced by national market surveillance authorities. Luxembourg's bill 8476, filed on 23 December 2024, would designate the Commissariat aux Assurances as market surveillance authority whenever an AI system is placed on the market, put into service or used by an entity it supervises (Article 7(4) as filed). The bill gives the audiovisual regulator only the Article 50(2) and 50(4) content duties (Article 7(8)). The Chamber of Deputies' dossier, as observed on 27 September 2026, shows the bill in committee, with no step recorded after 10 July 2026. Until the bill is enacted, does the Commissariat aux Assurances consider itself able to check an insurer's compliance with Article 50(1), or does no Luxembourg authority yet hold that power?
Why this band: No company's own account could be tested, so the question rests on the EU law, the bill and the parliamentary record.The EU's AI-disclosure duty has applied to insurers in Luxembourg since 2 August 2026, but the national law that would make the insurance supervisor the enforcing authority was in parliamentary committee as of 27 September 2026. The Commissariat aux Assurances has not publicly said whether it can act on that duty before the law passes. We found no regulator or company publication documenting AI use in underwriting, claims or pricing in Luxembourg. Press reports describe AI use by at least one Luxembourg insurer, which we could not confirm from a primary source.
3. What the open question means for firms in Luxembourg
Until the Commissariat answers, an insurer in Luxembourg running a customer-facing AI system has no published statement on whether any Luxembourg authority can check its Article 50(1) duty before the bill is passed. This entry gives no band to any firm.
4. What this entry does not establish
- Whether committee amendments have changed the bill's Article 7.
- Whether any interim arrangement exists. None was found; the question asks.
- The Commissariat's full index of circular letters was not read.
- Whether any Luxembourg insurer uses AI in underwriting, claims or pricing. No regulator or company publication documenting such use was found; press reports describe AI use by at least one Luxembourg insurer, which could not be confirmed from a primary source.
- 2 December 2026: the grace period for Article 50(2) marking ends.
- No date set: a vote on bill 8476 or its publication.
Sources
- Projet de loi n° 8476, deposited 23.12.2024 (printed). Bill, French. chd.lu PDF
- Chambre des Députés, dossier parlementaire 8476 (observed 27 September 2026). Parliamentary record. chd.lu
- CNPD, "AI Act: Coming into effect of new obligations on 2 August 2025", 18/08/2025 (printed). Regulator. cnpd.public.lu
- European Commission, FAQ on transparency obligations under Article 50 of the AI Act, last updated 24 July 2026 (printed). EU law (Commission guidance). digital-strategy.ec.europa.eu
- EIOPA, GenAI market survey release, 2 February 2026 (printed). EU authority. eiopa.europa.eu
- Regulation (EU) 2024/1689 (AI Act), Article 50(1), read on a secondary host. EU law. artificialintelligenceact.eu
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Commercial relationship with any party named here: None · Right of reply: indexreport.protocol@fijishi.com; with the sender's agreement, replies are published in full below the entry, dated · Cite as: Fijishi Jurisdiction Index 2026, Entry LU · Corrections: none.