I need to bring my Luxembourg organisation into compliance with recital 145 of AI Act (UE 2024/1689). What are the concrete requirements, the sanctions, and how can Luxgap support me?

Recital 145 AI Act — Recital 145 · official text + guide

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Recital 145

Artificial Intelligence Act · UE 2024/1689

(145)

In order to minimise the risks to implementation resulting from lack of knowledge and expertise in the market as well as to facilitate compliance of providers, in particular SMEs, including start-ups, and notified bodies with their obligations under this Regulation, the AI-on-demand platform, the European Digital Innovation Hubs and the testing and experimentation facilities established by the Commission and the Member States at Union or national level should contribute to the implementation of this Regulation. Within their respective mission and fields of competence, the AI-on-demand platform, the European Digital Innovation Hubs and the testing and experimentation Facilities are able to provide in particular technical and scientific support to providers and notified bodies.

Luxembourg specificity

Règlement (UE) 2024/1689 art. 57 et 62 ; programme Digital Europe ; écosystème Luxinnovation / L-DIH

In Luxembourg, the AI market surveillance authority has not yet been formally designated. The national resources available under recital 145 are concretely the L-DIH (European Digital Innovation Hub Luxembourg) operated by Luxinnovation, LIST and the SnT of the University of Luxembourg for scientific validation, as well as European TEFs to which Luxembourg actors can apply (notably TEF Health and TEF AgriFood). The future Luxembourg AI regulatory sandbox, foreseen by Article 57 of the Regulation, must be operational by 2 August 2026 at the latest.

Luxgap practice: we support the preparation of your L-DIH application and the identification of Luxinnovation co-funding (Fit 4 Digital Innovation, Fit 4 Innovation) that can be combined with your AI Act compliance effort, turning your compliance work into a subsidised R&D lever.

Luxgap guidance · DPO & CISO

How to comply

The classic trap

This recital imposes no direct obligation, but it sheds light on a crucial point: the legislator acknowledges that Luxembourg SMEs and start-ups will struggle to comply alone. Providers who ignore the available resources (AI-on-demand platform, European Digital Innovation Hubs, Testing and Experimentation Facilities) end up reinventing the wheel, paying for overpriced external audits, and facing the EU AI Office or Luxembourg's future AI market surveillance authority without any documented compliance effort.

How to concretely leverage the resources foreseen by recital 145

European Digital Innovation Hub Luxembourg (L-DIH): national gateway for test-before-invest, funding, AI skills access and the European EDIH network.
AI-on-demand platform (AIoD): European catalogue of models, datasets and tools your teams can reuse before building in-house.
Testing and Experimentation Facilities (TEFs): sectoral environments (health, manufacturing, smart cities, agri-food) to test an AI system under real conditions before market placement.
LIST and SnT Luxembourg: applied research resources you can mobilise for the scientific validation of high-risk AI systems.
AI regulatory sandbox: each Member State must establish one (Article 57), a concrete opportunity to test a high-risk use case under supervision of the competent authority.

Practical trap: these resources are free or subsidised, but their articulation with your compliance file (governance, risk management, Article 11 technical documentation, human oversight) remains your responsibility. A test at L-DIH does not equal CE marking.

How Luxgap automates this risk

Our Luxgap AI Compliance Accelerator turns the promise of recital 145 into an operational roadmap for your Luxembourg SME or start-up. The tool automatically maps your AI systems (internal LLMs, ML models embedded in Odoo/Salesforce, SaaS AI agents), qualifies them by AI Act risk level, then identifies for each use case the relevant public resource (L-DIH, sectoral TEF, AIoD, future LU sandbox) as well as financial aid available through Luxinnovation and the Digital Europe programme.

Automatically detects AI systems in production via connectors to M365 Copilot, Azure AI Foundry, AWS Bedrock, Google Vertex and the Odoo third-party extension catalogue.
Classifies each system against the AI Act grid (prohibited, high-risk, limited risk, minimal risk) based on Annexes I to III and EU AI Office guidelines.
Generates a preformatted application file for the L-DIH or a European TEF, including technical description, use case and identified testing needs.
Calculates an eligibility score for Digital Europe, Horizon Europe and Luxinnovation grants for each AI system under development.
Produces a timestamped PDF that evidences your proactive mobilisation of public resources, enforceable before the EU AI Office and Luxembourg's future authority during a market audit.
Tracks in real time the publication of CEN-CENELEC JTC 21 harmonised standards and alerts as soon as a standard applicable to your system is published in the OJEU.

Available as a complement to a Luxgap DPO or CISO mandate or as a dedicated SaaS module depending on your scope. Request a tailored quote and our teams will prepare a demonstration on your real AI systems, with a free blank audit within 48h to measure your exposure before any engagement.

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