Artificial intelligence is becoming a permanent component of employment relationships.
In Luxembourg, its progressive integration raises major legal challenges, particularly regarding labour law, individual freedoms, and governance.
Whether through the automation of certain functions, the use of algorithms in recruitment processes, or the increased surveillance of employees, AI prompts numerous legal questions.
The adoption of Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 (AI Act), some of whose provisions have applied since February 2025, further reinforces the need to address these emerging issues.
Automation is undeniably transforming professions and operational processes. Companies must now clarify their role in the value chain in light of the AI Act and ensure compliance with new risk management obligations.
AI now enables continuous and automated monitoring of employees. However, any surveillance mechanism must respect the right to privacy, proportionality, and transparency, in accordance with the Labour Code and the GDPR.
Algorithmic recruitment tools also raise concerns. If poorly designed, they can lead to discrimination, contrary to the principle of equal treatment. Employers must therefore ensure fairness, transparency, and auditability in the tools they deploy. The AI Act classifies AI systems used to select, assess, or assign tasks to employees as “high-risk”. Their use is therefore strictly regulated and requires dedicated governance.
Non-compliance with the AI Act may expose companies, as of August 2025, to sanctions of up to €15 million or 3% of their global annual turnover.
The introduction of artificial intelligence in the workplace challenges Luxembourg labour law on multiple fronts: job transformation, employee surveillance, algorithmic discrimination, and social dialogue. While these technologies offer new opportunities, they demand a rigorous legal framework, grounded in the principles of human dignity, proportionality, and transparency.
The Luxembourg legal framework, reinforced by European law, provides a solid foundation for the ethical and responsible integration of AI into the world of work.
Martin & Condrotte assists you in anticipating and implementing your obligations under the Artificial Intelligence Regulation.