On Thursday 5 November 2026, the Association of the Luxembourg Fund Industry (ALFI) published the first edition of its "AI in Asset Management" survey, offering insights into how Luxembourg's asset management industry is adopting artificial intelligence and addressing the challenges of its implementation.
According to the report, about 81% of surveyed asset managers remain at an early or intermediate stage of AI adoption, while around 19% have reached scaled or advanced implementation, predominantly among larger firms. The survey found that 97% reported adoption of generative AI, while already over 60% indicated engagement with emerging agentic AI. Furthermore, 92% had implemented formal AI governance policies, but operational practices remained uneven. While 98% reported human oversight of AI, only 52% adapted the level of review to the risk associated with individual use cases.
Prepared by ALFI and members of its Digital/FinTech Technical Committee as part of a broader European initiative led by the European Fund and Asset Management Association (EFAMA), the survey drew on responses from 63 asset managers and financial institutions of varying sizes. It examined AI adoption across six dimensions: strategy and governance, use cases and operational deployment, risk management and trustworthiness, technology, investment and ROI measurement, and workforce transformation.
The findings pointed to an industry moving beyond initial experimentation, although the ability to deploy AI at scale remained uneven: only around one in five respondents had reached an advanced or scaled stage of implementation. Nearly two-thirds of respondents identified data quality and availability as the main barrier to deployment, followed by internal expertise (48%) and difficulties measuring return on investment (44%).
Rawad Rouhana, Industry Affairs Adviser at ALFI, said: "AI is no longer an experiment for Luxembourg's fund industry. The real challenge now is scaling its use. Nearly 97% of respondents report using generative AI, but far fewer have translated that use into lasting operational change: around 19% report scaled or advanced adoption. Bridging that gap will require reliable data, the right skills and clear ways to measure the benefits."
According to the survey, asset managers are strengthening AI oversight, with over 80% reporting regularly to their board or senior management. With governance models maturing, 67% have already designated formal AI roles, building the foundations for broader adoption of bias and risk assessments. Furthermore, fewer than half conduct bias assessments.
Ulf Herbig, co-chair of the ALFI Digital/FinTech Technical Committee, stated: "As AI becomes more deeply embedded in business processes, asset managers need clear accountability and a robust, risk-based control and evaluation framework. Closing the gap between policies and implementation will be essential to building trust in AI and to scale adoption."
The survey also highlighted AI's impact on the workforce. Document analysis is currently the leading AI use case in production, followed by IT development and investment research. Around half of respondents expected AI to lead to a reallocation of roles, while overall headcount was generally expected to remain stable. Although training initiatives were widespread, formal reskilling programmes remained limited.
Hatice Baskaya, co-chair of the ALFI Digital/FinTech Technical Committee, commented: "AI is not just changing how tasks are performed, but also how work is organised. The challenge for asset managers will be to anticipate these changes and equip their employees with the skills they need. General AI training is a starting point, but more targeted workforce transformation programmes will be essential."
Looking ahead, the survey identified four priorities for scaling AI: strengthening governance and accountability, embedding risk-based controls, measuring business value and preparing the workforce for change. Despite the challenges, nine in ten respondents expected to increase their investment in AI over the next three years, signalling continued confidence in its potential