AMF activity Appointment Journalists End of the term of office of the AMF chairman and interim chairmanship
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Market infrastructures Post-trading infrastructures EMIR Common procedures and methodologies on supervisory review and evaluation process of CCPs under Article 21 of EMIR: the AMF complies with ESMA guidelines
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Asset management Savings protection Journalists The AMF is conducting a consultation on the end of life of private equity funds intended for retail investors
The AMF is conducting a consultation on regulatory reforms governing the end-of-life management of retail private equity funds (FCPRs, FCPIs, and FIPs), with the objective of improving compliance with liquidation deadlines and enhancing investor protection through better information disclosure and operational safeguards. This initiative addresses systemic issues where fund managers have historically failed to respect contractual lifespan commitments, creating liquidity risks and investor communication failures.
What Changed
The AMF has amended its General Regulation and policy framework to implement several substantive requirements:
*Liquidation Compliance & Warnings**
A new Article 422-120-14-1 requires management companies to include a warning in promotional materials if, over the ten years preceding fund authorization, the company failed to respect the lifespan of at least 50% of retail or professional private equity funds under its management. This warning applies only when two materiality thresholds are met:
What You Need To Do
- *For All Retail Private Equity Fund Managers
- *Audit historical compliance with fund lifespan commitments over the preceding ten years to determine if warning requirements under Article 422-120-14-1 apply
- *Implement bank details collection for all funds established after December 5, 2024, incorporating requirements into subscription forms per Instruction DOC-2011-22
- *Establish prior notification procedures for substantial changes to fund structure, investment strategy, or operations, with one-month advance notice to the AMF
- *Update Position-Recommendation DOC-2012-11 compliance to reflect the extended 15-year lock-up period for newly authorized funds
Key Dates
December 5, 2024 - Effective date for new Article 422-120-16 (bank details collection requirement for newly established funds)
November 12, 2024 - AMF decision approving amendments to General Regulation
December 5, 2024 - Publication in Official Journal of the French Republic
June 13, 2024 - Enactment of Attractiveness Law No. 2024-537 (establishing 15-year maximum lock-up period)
January 10, 2024 - Revised ELTIF Regulation came into application
Compliance Impact
Urgency: HIGH
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Regulatory developments Europe & international Sustainable Finance Periodic & ongoing disclosures AMF's response to the International Sustainability Standards Board’s consultation on the exposure drafts on international sustainability disclosures
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, issued a position paper on July 27, 2022, responding to the International Sustainability Standards Board's (ISSB) consultation on exposure drafts for international sustainability disclosure standards (IFRS S1 and S2). This matters for compliance professionals as it signals France's push for global-EU interoperability in ESG reporting, influencing how firms align ISSB "investor-focused" standards with Europe's double-materiality CSRD/ESRS framework to avoid dual reporting burdens. https://www.amf-france.org/en/news-publications/amfs-eu-positions/amf-response-issb-consultation-exposure-drafts-sustainability-disclosure-standards; https://www.amf-france.org/sites/institutionnel/files/private/2022-07/Position%20paper%20ISSB%20AMF%20-%20July%202022_0.pdf
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What Changed
This is not a new regulation but AMF's recommendations to ISSB, emphasizing:
Interoperability with EU standards: AMF urges alignment between ISSB's financial materiality approach and EFRAG's double-materiality (impact + financial) ESRS, including jurisdictional working groups for compatibility.
Broad ESG coverage: Calls for sector-agnostic standards beyond climate (e.g., full ESG spectrum via collaboration with EFRAG/GRI).
Phased implementation: Suggests gradual rollout of detailed requirements
What You Need To Do
- Monitor and map standards
- Engage in transitions
- Enhance reporting processes
- Stakeholder dialogue
Compliance Impact
Urgency: Medium. This 2022 AMF response is historical but highly relevant amid 2025 EFRAG simplifications emphasizing ISSB interoperability, as EU firms juggle CSRD with global ISSB momentum (e.g., IFRS finals in 2023). Matters for avoiding reporting fragmentation, with risks of supervisory scrutiny
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Regulatory developments Europe & international Sustainable Finance Periodic & ongoing disclosures AMF's response to the EFRAG consultation on the draft European sustainability reporting standards
The AMF's position paper responds to EFRAG's 2022 public consultation on the first set of draft European Sustainability Reporting Standards (ESRS) under the CSRD, welcoming their ambition on ESG topics and double materiality while urging proportionality, international interoperability, materiality focus, and alignment with EU laws like SFDR. This matters for compliance professionals as it shapes final ESRS, influencing mandatory sustainability disclosures for EU firms and financial market participants from 2024 onward, with potential simplifications affecting reporting burdens. https://www.amf-france.org/en/news-publications/news/amfs-response-efrag-consultation-draft-european-sustainability-reporting-standards
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What Changed
This is a consultation response, not a final rule, but AMF highlights these priorities for ESRS development:
International interoperability: Convergence with ISSB standards to avoid duplication and meet investor needs across jurisdictions. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
Proportionality in disclosures: Gradual implementation, prioritizing climate standards, balancing stakeho
What You Need To Do
- Monitor ESRS evolution
- Enhance materiality processes
- Align reporting systems
- Engage stakeholders
- Pilot disclosures
Key Dates
July 2022 - AMF submits response to EFRAG consultation on draft ESRS. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2024 - First CSRD application for FY 2024 reports (large public-interest entities). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2025 - ESRS adoption by European Commission (first set covering SFDR needs). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf
2027 - Potential application of simplified ESRS (per EC quick fix hints). https://www.gibsondunn.com/efrag-releases-draft-simplified-european-sustainability-reporting-standards-esrs/
TBD (post-2025) - EC Delegated Act on simplified ESRS, subject to 2-month EU Parliament/Council scrutiny. https://www.efrag.org/en/news-and-calendar/news/efrag-provides-its-technical-advice-on-draft-simplified-esrs-to-the-european-commission
Compliance Impact
Urgency: Medium - Historical (2022) input shapes binding ESRS already applying in 2024/2025, but ongoing simplifications (e.g., 2025 EC advice) offer relief on burdens; critical for FY2026+ prep amid interoperability push, yet not immediate mandates. Matters for reducing overload, ensuring SFDR comp
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MiCA Crypto-assets Innovation Cooperation Europe & international Crypto-asset markets: Agreement reached on the European Crypto-Assets regulation (MiCA)
Crypto ExchangeFintech
Sanctions & settlements Compliance Journalists Investment services providers The AMF Enforcement Committee fines a depositary for breaches of its professional obligations
The AMF Enforcement Committee fined RBC Investor Services Bank France SA (RBC ISBF) €500,000 plus a warning on 20 July 2022 (published 08 January 2026) for breaches as a UCITS and AIF depositary, including 25 confirmed failures in tiered intervention procedures for investment ratio overruns and deficient monitoring of 14 questionable cash flows over 45 months. This decision underscores AMF's strict enforcement of depositary duties under French regulations implementing UCITS/AIFMD, emphasizing robust controls for ratio compliance, cash flow verification, and documentation. It matters for compliance teams as it provides precedent on what constitutes "irregular and deficient" oversight, potentially increasing scrutiny and fines for similar lapses in depositary functions.
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What Changed
This is an enforcement decision, not a new regulation, but it clarifies and reinforces existing depositary obligations under French UCITS/AIFMD rules (e.g., Articles L. 214-7 et seq. Monetary and Financial Code):
Ratio monitoring and intervention: Depositaries must implement tiered procedures for investment/asset composition ratio breaches (e.g., diversification limits); 25 of 28 alleged anomalies were upheld due to redundant but confirmed procedural failures.
Cash flow oversight: Must identify
What You Need To Do
- Review depositary controls
- Enhance cash flow monitoring
- Conduct gap analysis
- Update policies/procedures
- Appeal if applicable
Key Dates
20 July 2022 - AMF Enforcement Committee decision date imposing €500,000 fine and warning on RBC ISBF.
08 January 2026 - Public news release/publication date of the decision.
Compliance Impact
Urgency: Medium – Recent publication (08 January 2026) signals ongoing AMF focus on depositary failings amid H2O-related probes, but stems from 2022 events with no immediate deadlines. Matters because it sets precedents for fine quantum (€500k) on procedural lapses, reinforces liability for cash/rat
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Savings protection Cooperation Crypto-assets Fintech Journalists The AMF and the ARPP are stepping up their cooperation to promote clear and responsible advertising of financial products
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Bids Financial disclosures & corporate financing The AMF reviews the key issues raised by the Veolia-Suez public offer
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Sanctions & settlements Journalists The AMF Enforcement Committee fines one natural person and five legal entities, including a management company, for failing to comply with several reporting obligations in relation to a concerted action carried out in the context of a takeover bid and, in the case of the...
The AMF Enforcement Committee imposed fines on one natural person and five legal entities, including an investment management company, for failing to comply with multiple reporting obligations related to a concerted action during a partial takeover bid.[User Query]. This enforcement action underscores the AMF's strict enforcement of transparency rules in takeover scenarios, serving as a critical reminder for market participants to adhere to disclosure timelines to avoid significant financial penalties and reputational damage.
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What Changed
This is not a regulatory change or new requirement but an enforcement decision highlighting existing obligations under French financial markets law, particularly those governing concerted actions (actions concertées) and reporting in takeover bids. Key requirements reinforced include:
Timely disclosure of positions and intentions when parties act in concert, as per AMF regulations on major holdings and takeover bids (e.g., Article L. 233-10 of the French Commercial Code and AMF General Regulatio
What You Need To Do
- Review and enhance internal procedures for monitoring share positions, identifying concerted actions, and automating AMF filings
- Train front-office and compliance teams on takeover bid disclosures, including documentation of coordination (e
- Implement pre-trade alerts for threshold breaches and conduct periodic audits of historical filings
- For management companies
Key Dates
Within 4 trading days - Declaration of crossing major holding thresholds or intent to continue acquisitions (AMF Form DOC-2005-01).
Immediate (same day) - Notification of concerted action agreements in takeover contexts.
Within 10 trading days - Detailed position reports post-crossing.
in 2025 (e.g., 16 July 2025 for inside information breaches).
Compliance Impact
Urgency: High - This matters due to the AMF Enforcement Committee's pattern of fining reporting failures (e.g., €1.89M in July 2025 for late disclosures, €1.7M in June 2025 for shareholder breaches), signaling intensified scrutiny on M&A transparency amid volatile markets. Non-compliance risks fines
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Derivatives or structured products Journalists The AMF has published a study of the profile of participants and their positions in the Matif agricultural commodities derivatives market
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Sanctions & settlements Journalists The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations
The AMF Enforcement Committee fined an unnamed portfolio asset management company €400,000 for multiple breaches of professional obligations, including non-operational investment/divestment procedures, inadequate conflict of interest management with group service providers, lack of transparency on distributor fee retrocessions, deficient client categorization, and weak AML/CFT due diligence. This enforcement action, mirroring recent similar cases against firms like Novaxia Investissement and Eternam, underscores the AMF's heightened scrutiny on operational robustness and transparency in asset management, serving as a critical reminder for firms to ensure procedures are fully implemented and documented to avoid personal liability for executives.
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What Changed
This is an enforcement decision rather than new legislation, but it reinforces and clarifies existing regulatory requirements under AMF professional obligations for portfolio asset managers (sociétés de gestion de portefeuille). Key emphases include:
Investment/divestment processes must be fully operational, with traceability of compliance checks against fund policies and formalized due diligence before allocations.
Effective conflicts of interest policies are mandatory when using group service
What You Need To Do
- Audit internal procedures
- Enhance conflict and transparency controls
- Strengthen AML/CFT and client categorization
- Senior manager accountability
- Mock AMF inspections
Key Dates
9 September 2025 - AMF Enforcement Committee decision fining Eternam €400,000 (similar case on marketing, club deals, conflicts, valuation, AML/CFT).
10 December 2025 - AMF Enforcement Committee decision fining Novaxia Investissement €400,000 and director €100,000 (investment processes, group providers, distributor fees, client categorization, AML/CFT).
31 December 2025 - AMF Enforcement Committee decision fining M Capital Partners €200,000 and directors €70,000/€35,000 (investment systems, conflicts, AML/CFT).
Compliance Impact
Urgency: High - Recent cluster of identical fines (€200k-€500k total per case) in late 2025 signals AMF's enforcement priority on operational deficiencies in asset management, with personal sanctions escalating risks for leadership. Firms with similar setups (group providers, AIFs/club deals) face i
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Supervision MAR Journalists Investment services providers Investment management companies Publication of the SPOT inspection campaign summary on market abuse prevention systems in asset management companies
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Risk and Trend Mapping Markets Europe & international Asset management Executive & other private individuals Journalists Investment services providers Investment management companies Listed companies and issuers The...
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Supervision MIFID Journalists Investment services providers Investment management companies The AMF publishes a summary of its SPOT inspections on the theme of best execution in asset management companies
Asset Manager
AMF activity Appointment Journalists Grégoire Vuarlot is appointed coordinator of the ACPR and AMF Joint Unit starting 1st July 2022
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Innovation AMF activity Journalists Investment services providers Investment management companies Listed companies and issuers The AMF continues its data strategy with the release of short selling data to the public
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Crypto-assets Innovation Market infrastructures on blockchain technology: publication of the European Pilot Regime regulation
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