Luxembourg Talent Market Report - December 2025

ATAD 3 - a looming EU draft tax directive - a must read if you aren't yet aware.... ATAD 3, an EU wide anti-tax avoidance directive which is set to be ratified by the European Parliament during the summer of 2023, and is expected to be effective as of early 2024 across all EU member states. Its a noteworthy piece of legislation that may well make quite an entrance into the Luxembourg funds and corporate holding context. ATAD 3 aims to tackle anti-tax avoidance measures and will have a particular focus on substance of concerned entities. Tests to determine whether an entity can demonstrate sufficient substance are thought to have potentially seismic shifts in how managers will be required to structure their Luxembourg holding structures in such was as to avoid triggering tax liabilities under these potential new rules. We foresee the out-workings on the Luxembourg labour market being impacted in a several potential ways: Changes in corporate structures: ATAD 3 could require companies to restructure their operations requiring them to have far greater more substance in Luxembourg. This could involve moving employees from other locations to Luxembourg, or hiring new local employees to meet the substance requirements. This could potentially lead to an increase in demand for skilled professionals in certain sectors and thus likely creating further talent shortages in other existing traditional areas. Impact on the overall economy: The implementation of ATAD 3 could be both a positive and negative on the overall economy in Luxembourg. Historically greater regulatory or substance pressures have tended to aid Luxembourgs employment market, however this is a delicate balance and could where percieved draconian measures could in fact damage the competitiveness of the unique dynamics of the Lux market. Increased demand for tax experts: ATAD 3 introduces new and complex rules to prevent tax avoidance. This will invariably lead to an increased demand for tax advisory. New tax legislation for some is always a good thing. Overall, the impact of ATAD 3 on the Luxembourg funds and corporate industry is likely to be significant, as many funds operate on a cross-border basis and may be affected by the new rules on hybrid mismatches and interest limitation. However, Luxembourg has a strong reputation as a fund domicile and flexible corporate domicile known for its expertise in tax-efficient structuring. As such, industry is likely to adapt to the new rules and continue to be an attractive destination for managers and investors alike. Happy to brainstorm this further with anyone that might also be interested in the topic! First Published Feb 2023 AGEFI Courtney Charlton

Attracting Talent: The Power of The Candidate Journey Whilst a slowdown in many employment sectors of Luxembourg has been observed in recent months, the labour market remains fiercely competitive. Might now be the moment for employers to take stock of their competitiveness as being an employer of choice? Reputational risk is a factor that we all too regularly underestimate as employers, yet it is a factor that has immense impact on a firms efficiency in being able to secure talent. In a market as incestuous as Luxembourg, there is no doubt that this a factor that can be decisive in achieving the most desirable outcomes for recruitment initiatives at all levels. The Long-lasting Impact of the Candidate Journey: The candidate journey encompasses the entire experience an individual has when interacting with a company, from the initial application to the onboarding process. However, in my observation many employers overlook this series of touchpoints and their lasting and critical nature. Failing to realise the impact these experiences have can adversely affect their reputation and by extension, their ability to attract talent in the longer-term. A firm that consistently delivers an unfavorable candidate journey risks tarnishing its organization's reputation, resulting in a widespread negative perception that deters potential candidates from considering employment opportunities. Much of our talent pool is international in its construct, social and well-networked. People love to relay their employment and interview experiences. Sentiment and anecdote whether they be positive or negative will likely be accentuated and are therefore hugely important factors of reference. For these reasons, a tarnished employer image usually spreads exponentially and with pace once it takes hold. Facts are often replaced with conjuncture and hear-say which nevertheless can build to gain significant momentum leading to either positive or negative outcomes. Tactics for Enhancing the Candidate Experience: It is crucial for employers to understand the significance of each touchpoint and create a positive and memorable experience throughout the candidate journey. Clear and Transparent Communication: Effective communication is key to building trust and maintaining transparency with candidates. Regular updates, timely responses, and clear expectations throughout the recruitment process foster a positive experience. Streamlined Application Process: Simplify the application process to minimize candidate frustration. Lengthy, convoluted hurdles and excessive documentation requirements can deter potential applicants and leave negative impressions. A user-resource-friendly and efficient process demonstrates respect for candidates' time and effort. Personalised Candidate Experience: Tailoring the recruitment journey to the individual can leave a lasting impression. Personalised interactions, such as sincerely engaging and acknowledging their specific skills and experiences, showcase a company's genuine interest in them. Positive Interviewing Experience: Conducting interviews in a respectful, engaging, and professional manner demonstrates a company's commitment to treating candidates with respect. Ensuring interviewers are well-prepared, asking relevant questions, and providing feedback can significantly enhance the overall experience. Constructive feedback: we all need this; not least when we have dedicated ourselves to a recruitment process and have not been successful. Pragmatic and non-personal feedback is always welcomed and highly appreciated. Consistent Employer Branding: Align the candidate journey with the company's employer brand. Ensure that the messaging, values, and culture conveyed during the recruitment process are consistent with the organisation's overall image. This consistency helps build trust and credibility. External partners: All parties that the firm interacts with have the potential to be local ambassadors. Your suppliers, partners and service providers are all potential employees as well as advocates. Treat your external counterparties as you would those internally. Recognising the significance of the Candidate Experience as a reputation building factor is paramount for companies striving to gain an advantage in a competitive talent market. By focusing on authenticity, prioritizing the employee experience, crafting a compelling employer value proposition, employers can become a employer of choice and attract top talent in Luxembourg's tight employment market. Courtney Charlton is the co-founder of Greenfield Luxembourg and the head of Executive Search. First published AGEFI Luxembourg June 2023

Introduction: A Market Redefining Itself The past three years have reshaped Luxembourgs talent landscape in ways few anticipated. After a deep freeze in 2023 and a tentative recovery throughout 2024, the market in 2025 has regained momentum, but in a far more controlled and deliberate manner than before. Across the asset management, financial sector and wider economy, a consistent theme has emerged in our conversations with senior leaders: hiring has returned, but the urgency has not. The era of aggressive competition and rapid-fire offers has given way to a much more measured approach, where the focus has shifted decisively toward securing individuals who genuinely influence outcomes. This report brings together the strongest insights from our direct perspective and reflects the candid views shared by business and HR leadership in the second half of 2025, navigating a market that rewards precision, readiness and a new way of thinking about talent. How 2025 Actually Played Out A Year of Activity, But Marked by Volatility. There is a broad consensus that 2025 has been an improvement on 2024. According to Greenfields new vacancies data - more mandates were created (+29 percent on 2024), particularly in the spring, and movement across mid-level finance, governance and legal roles accelerated. Yet the year has been characterised by striking inconsistency. Periods of high demand were often followed by weeks of relative stillness, and the summer months were notably subdued, with many organisations postponing decisions longer than usual.Recruiters and hiring managers alike describe the year as one defined by peaks and troughs, reflecting a market that has not yet established a stable rhythm. Cautious Optimism Defines the Mood Despite solid market performance and ongoing deal activity, confidence across the financial sector remains cautious. Liquidity constraints, sovereign debt and geopolitical uncertainty continue to exert a subtle but persistent influence on hiring behaviour.As one banking executive remarked, We keep waiting for the music to stop, but it keeps playing. This neatly encapsulates the prevailing sentiment: cautiously forward-moving, yet consistently aware of risk.

Navigating the Challenges and Opportunities of Simplified Right to Work for Third Country Nationals in Luxembourg Third Country Nationals in Luxembourg Under the Law of 7th August 2023, and amending the law of 29 August 2008 on the free movement of persons and immigration, Starting September 1st, 2023, businesses employing third-country nationals in high-demand professions, which are those facing shortages of labor in the EU market, will no longer undergo a labor market test. Instead, they can swiftly obtain approval from the Employment Development Agency within five working days upon requesting permission to hire these individuals. Formerly, such companies were required to wait for a labor market test lasting three weeks or more before receiving certification which often was prohibitive to progressing third-country nationals to an offer of employment. High demand professions: The specific professions considered as high-demand in Luxembourg may vary based on the country's economic needs, industry trends, and demographic factors. A complete current list is available at Legilux.public.lu however they span across all sectors, from hospitality, IT, healthcare and unsurprisingly, finance. Employers wishing to employ third-country nationals for roles outside of these defined functions will still require undergoing a lengthier formalisation process. Opportunities: Attracting Talent: Luxembourg has a skills shortage; this is without question. Even today, in an economic squeeze, we observe full employment and a continued war for talent within certain segments of the market. Simplifying the access to overseas talent will open-up new avenues of exploration for some employers and should be considered as beneficial to the nation. Accessing this talent effectively will remain a challenge and will require a paradigm shift in talent acquisition strategy for both HR leaders and external consultants. Economic Growth: Enabling greater access to the market will naturally stimulate the acquisition of formerly unreachable talent; this may in turn my encourage foreign investment and domestic entrepreneurship to select Luxembourg as a base market where this would otherwise have not been the case. There are various sectors of development that the Luxembourg state has committed to support which may also benefit from this drive. An influx of formerly inaccessible talent may contribute to the development of emerging industries and enhance the country's competitiveness; a topic of considerable significance. Cultural Diversity: Luxembourg is a melting-pot of diversity. This is not a new concept and it is arguably one of our richest national characteristics. We are excellently positioned to embrace an ever more diverse workforce and continue to foster cross-cultural exchange. There is no doubt that Luxembourg is a leader in leveraging strength through diversity and is debatably a beacon of this enhancement within a wider European context. Challenges: Strain on housing stock: Luxembourgs robust population growth in the last decade of around 2.0% annually continues to strain existing provisions. Despite efforts to increase housing supply, Luxembourg continues to face shortages and therefore a spiraling rental market. The intended desire to increase the population by stimulating the ease of access to the employment market will without doubt further exacerbate this topic. Without an ample supply of affordable housing schemes and a more substantial public transport system outside the City and principal urbanisations, will surely lead to further strain on a very vulnerable system even further. Integration and Social Cohesion: Ensuring the smooth integration of expatriates into Luxembourg's society poses a significant challenge. Language barriers, cultural and religious differences can lead to a progressive erosion the existing social structure of the country. This is commonly understood to already be the case and further work must be undertaken to ensure that ample provision of common services and resources to cater for a wider spectrum and growing population of non-European immigrants. This is a substantial challenge facing such a small and traditionally conservative country as Luxembourg. Labor Market Dynamics: The loosening of right to work requirements will arguably stimulate competition in the labor market. Luxembourg which has long walked a narrow path of being both competitive in an international context, but also offering an enviable economic advantage to its labour force is exposed to shocks associated with a sudden oversupply of incoming labour. Luxembourg must strike a balance between leveraging foreign talent to enable growth but equally to safeguard salary stability and job security for the domestic labour pool. This requires proactive labor market policies including ongoing training and upskilling initiatives across all industries. The practicalities of elegantly managing incoming offers of labour from a new third-country population will be a challenge. Markets are highly connected and information travels fast. There is already very substantial interest from would-be labour from all continents. Nuance and cultural understanding of Luxembourgs norms are however learnt and not inherent. Frustration by parties on either side the employment offer may become evident. On one hand there is now in principle, little restriction for overseas immigrants to obtain employment in Luxembourg, we are after all offer a highly attractive market with the highest minimum wage in the EU, but on the other, there are practical realities of possessing the necessary relevant skills, language and cultural norms that all come to make an employment relationship work. Employers will need to be prepared for this challenge it will be both sensitive and time consuming. Employer branding may be challenged, and special attention must be observed to ensure equal opportunities for all qualified applicants. A joined-up approach with both industry and the Employment Development Agency should be actively sought; only with this joined-up approach will there be the necessary policy and progress achieved. Courtney Charlton 13/2/24 First published AGEFI Luxembourg Feb 2024

Organisations continue to face the inherent challenges of a competitive job market; identifying and retaining top talent is a pivotal exercise for all modern companies. It is not unsurprising with this backdrop that in the advent of predictive analytics powered by artificial intelligence (AI) and machine learning, many larger firms have actively implemented technology that enables data-driven hiring decisions that promises to optimise candidate success and retention. As a professional recruiter I caution this topic with large dose of hesitancy. The theory is: traditional recruitment methods often rely on subjective assessments and gut instincts. It is said that this can lead to inefficiencies and mismatches between the candidate appointed, their respective job role, and cultural fit. The promise is that predictive analytics powered by artificial intelligence reduce these subjectivities. By leveraging vast amounts of historic data (related to candidates, employers, and job functions) they can identify correlations and trends that indicate probabilities of a given candidates success and retention and thus lead the hiring party to make talent acquisition decisions based upon a highly data-driven model. Whilst there are some notable opportunities in using AI to aid a recruitment process (efficiency, diversity, accuracy, and strategic talent management) where the use of technology is ill planned and executed without sufficient finesse, sensitivity, and temperance, I believe that there are significant long term negative consequences related to the introduction of bias and consequently, hiring discrimination. This has become a topic of debate with much anecdotical evidence demonstrating that the adoption of algorithmic tools has caused both inefficiency and in many cases taking what should be a human experience of hiring a future employee and turning it into what can be likened to an experience on a dating website. This is in its most optimistic sense highly impersonal, and at its extreme simply immoral. There is a real risk of systematic and unfair favoritism or prejudice that can (and does) influence algorithmic decision-making in talent acquisition initiatives. These biases can manifest in various forms, however, here are a few to consider: Historical Bias: AI algorithms are trained on historical data that may perpetuate and, in fact, magnify existing biases present in a companys hiring decisions. If historical data reflects systemic inequalities in former recruitment practices, AI models will probably reinforce these biases. Data Bias: Biases can also arise from the quality and representativeness of the data used to train AI algorithms. If training data is skewed or unrepresentative of the diverse population of job seekers, algorithms may produce biased outcomes that disproportionately disadvantage (or by extension provide advantage to) certain demographic groups. Consider, when applied to its fullest level of execution, AI will preselect without compromise only according to its trained criteria there are no opportunities for a qualitative decision; nor are there likely the means for a job seeker to challenge a decision executed. Algorithmic Bias: Due to the complexity of modeling human behavior and preferences, the programming of algorithmic code can in fact become invertedly bias. Factors such as feature selection, weighting, and decision thresholds can introduce unintended biases into AI driven decision-making processes. Feedback Loop Bias: Biased outcomes generated by AI algorithms may perpetuate feedback loops that reinforce inequalities in a firms talent acquisition processes. For example, if certain demographic groups are consistently overlooked or rejected by AI-driven tools they may be perpetuated in the algorithm of selection. AI has the potential to enhance talent acquisition by improving efficiency and facilitating data driven matches between candidates their job function and organisation. However, the potential for inhuman decision making can be very unfair. Organisations would be wise to address concerns related to bias and thus potential discrimination. There are further various considerations surrounding data privacy and transparency that need to be carefully monitored to ensure the ethical and responsible use of AI in recruitment initiatives. Predictive models require ongoing refinement and validation to remain accurate. User companies should therefore establish mechanisms for ongoing monitoring and evaluation of AI talent acquisition systems to detect and address emerging biases or disparities. Diversity is king for many organisations, lets ensure that this is not neglected. First published in AGEFI May 2024 Courtney Charlton

The Greenfield Conversation Episode 2 I sat down with Ami Nagata, Managing Director of Zodia Custody, to talk about her personal journey to executive leadership, the Crypto industry and her personal philosophies on leadership and personal development. Thanks to Ami Nagata - Zodia Custody for your insights and compelling approach to life - its a great watch! The Greenfield Conversation explores the personal journeys behind leadership in Luxembourgs financial ecosystem.

The Greenfield Conversation Episode 1: Johan Van den Berg, Group CEO, Ancorius In this insightful discussion, we explore what it means to build a client-centric business in Luxembourg, how to develop high-performing teams, and the leadership mindset required to thrive in a fast-moving financial ecosystem. Johan shares lessons from his own journey, the importance of trust and talent, and why staying close to clients is the foundation of lasting success. The Greenfield Conversation dives into the personal journeys behind leadership in Luxembourgs financial, funds, and digital-asset sectors. Real experiences. Honest insights. Lessons worth sharing. #GreenfieldConversation #Leadership #Luxembourg #FinancialServices #Ancorius #CareerJourneys

Why Having a Career Plan is Essential to your Professional Growth In today's fast-paced and ever-evolving professional landscape, the importance of having a career plan cannot be overstated. Whether you're just starting out or you're a seasoned professional, having a clear vision of where you want to go and how you plan to get there is crucial for achieving success and fulfillment in your career. But why is a career plan so essential? Let's explore the the key reasons. Defining Your Career Goals The foundation of any successful career plan starts with clearly defined career goals. Ask yourself: What are your career aspirations? Where do you see yourself in 2, 6, or 10 years from now? It's important to consider whether your current career trajectory aligns with your ideal path. Are you working in the right area of your field of expertise or even in the right discipline? Are you on a corporate career path, or are you leaning towards consulting or advisory roles? Are you already in your chosen market or can your skills be better suited to an alternative environment? These are pivotal questions that help shape your career plan. Without clearly stated goals, finding the right path can be challenging. Sure, invariably you will need to study, or pursue professional qualifications and you will be wise to build a professional network and gain valuable transferable experience along the way. However, without a clear picture of where you are heading, you might end up on the right path by luck rather than by design. The Pitfalls of Not Having a Career Plan Surprisingly, or perhaps not, many professionals across various industries are rarely mindful of their career planning. This often leads to a rudderless journey where progress is a result of chance rather than a deliberate, desired outcome. When professionals lack a clear career plan, their advancement tends to be sporadic and opportunistic rather than structured and intentional. This lack of direction can result in a career that feels unfulfilling and stagnant. Professionals may find themselves drifting from one job to another, motivated primarily by short-term incentives such as pay raises rather than long-term career growth and satisfaction. This approach rarely leads to sustained success and can leave individuals feeling unmotivated and disengaged. The Power of a Structured Career Plan Conversely, when I meet individuals with a clear goal and a structured thought process about what they want to achieve, they stand out as compelling prospects for our clients. These individuals exhibit: Direction and Focus Having a career plan provides a roadmap for success. It gives individuals a laser focus and drive to achieve their goals. This direction ensures that every step taken is purposeful and aligned with their long-term objectives. Certainty and Belief Professionals with a career plan have certainty and belief in their objectives. They are not swayed by short-term opportunities that might offer immediate rewards but do not align with their ultimate career goals. This steadfastness is a key trait of successful individuals. Motivation and Purpose A well-defined career plan instills a sense of motivation and purpose. It gives professionals a reason to strive for excellence and persevere through challenges. Knowing what you want to achieve and actively working towards it brings a sense of fulfillment and satisfaction. Long-term Success When I reconnect with professionals who had a clear career plan early on, they have invariably succeeded. Their structured approach to career planning and their unwavering focus on their goals have propelled them to achieve significant milestones in their careers. Crafting Your Career Plan Creating a career plan involves several key steps: Self-Assessment Start by assessing your strengths, weaknesses, interests, and values. Understanding what drives you and where your true passions lie is essential for setting meaningful career goals. Setting SMART Goals Set Specific, Measurable, Achievable, Relevant, and Time-bound (SMART) goals. These goals should be clearly defined and broken down into short-term and long-term objectives. For example, a short-term goal might be to obtain a particular certification, while a long-term goal could be to become a senior executive in your field. Research and Networking Conduct thorough research on the industry and roles you are interested in. Networking with professionals in your desired field can provide valuable insights and help you identify the skills and experiences needed to achieve your goals. Continuous Learning and Development Commit to continuous learning and development. This could involve pursuing additional qualifications, attending industry conferences, or engaging in professional development courses. Staying updated with industry trends and advancements will ensure you remain competitive and relevant. Regular Review and Adjustment A career plan is not static. Regularly review and adjust your plan based on your progress and any changes in your personal or professional circumstances. Flexibility is key to adapting to new opportunities and challenges that may arise. In Summary In essence, having career goals early in your career provides clarity, motivation, and a sense of purpose that are essential ingredients for success. By defining what you want to achieve and actively pursuing those goals, you increase your chances of realising your full potential and building a fulfilling and rewarding professional life. A career plan acts as a guiding compass, ensuring that you are always moving towards your desired destination, no matter what obstacles may come your way. In conclusion, investing time and effort into creating and following a career plan is not just beneficial but essential for professional growth. It empowers you to take control of your career trajectory, make informed decisions, and ultimately achieve the success and satisfaction you desire. So, take the first step today define your career goals and chart your path to professional growth and fulfillment. Courtney Charlton Original published in AGEFI June 2024

Winning the War for Talent: Addressing Client Pain Points and Elevating Recruitment Success The recruitment landscape is more competitive and complex than ever, with businesses struggling to attract, secure, and retain top talent. As a recruitment company, weve listened to our clients frustrations, observed recurring challenges, and identified actionable solutions to transform their hiring outcomes. Heres what weve uncovered and how clients can win the war for talent. The Common Pains of Recruitment Our clients challenges often boil down to a noisy and overcrowded market. With hundreds of unqualified applicants and limited time to screen effectively, many businesses feel overwhelmed. Budget constraints further complicate matters, limiting access to professional recruitment services that could lighten the load. Adding to this, discrepancies between HR and line management often lead to misaligned goals. HR teams may focus on budgets and process, while line managers prioritize candidate characteristics and skills, creating friction in decision-making. Moreover, limited expertise within HR or a lack of dedicated recruitment support means hiring managers are left juggling operational duties with recruitment execution. Common Complaints About the Luxembourg Labour Market Weve been reflecting on the most common frustrations of our clients when engaging with the Luxembourg recruitment market. Whilst many of these challenges are simply a product of the buoyant job market there are some practical recommendations that will help improve your chances of success in securing the most suitably talented people for your business: Accelerate Decision-Making: In-demand candidates are quickly secured in this competitive market. Streamlined processes and expedited decisions are critical. Prioritise Candidate Experience: A seamless and professional interview process from end to end - reflects positively on the organisation, enhancing its appeal. Align Compensation with Market Standards: Competitive remuneration aligned with industry benchmarks is essential to attract and retain talent. Develop a Robust Employer Value Proposition (EVP): Clearly articulate the organisations culture, mission, and opportunities to differentiate the role. Adopt Flexibility: Adjust working terms, be willing to train, and listen to recruiter recommendations to enable creativity in expanding your talent pool. Actively Engage in the Process: Avoid seeing recruitment as an event instead view each interview as a step in the process. Be patient, adapt, pivot and listen the realities of the market even if its not what you want to hear! Leverage Narrative: Craft a compelling organisational story that resonates with candidates and aligns with their aspirations. Engage Recruitment Expertise: Partnering with specialised professionals ensures access to market insights, tailored strategies, and optimal outcomes. Courtney Charlton February 2025