Sustainable Finance Periodic & ongoing disclosures Corporate sustainability reporting: AMF’s response to EFRAG’s consultation on the simplification of European standards
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, responded to EFRAG's July 31, 2025, public consultation on simplified European Sustainability Reporting Standards (ESRS) under the CSRD, welcoming a 57% reduction in mandatory datapoints and 55% shorter standards while urging refinements in materiality, climate reporting, and financial effects disclosure. This matters for compliance professionals as it signals upcoming proportionate ESRS revisions that could ease reporting burdens for large listed companies starting voluntarily in 2026, enhancing investor usability without diluting key sustainability insights.
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What Changed
AMF endorses EFRAG's simplifications but proposes targeted adjustments:
Materiality assessment: Support for proportionate double materiality (impacts, risks, opportunities or IRO) but requires minimum specification of impact type (positive/negative, risk, opportunity); prefers "gross" approach (pre-mitigation) over complex mitigated impacts for investor relevance and consistency.
Climate reporting: Regrets removal of "net zero" definition (90-95% gross GHG reduction trajectory), essential for 20
What You Need To Do
- Monitor EFRAG's post-consultation technical advice (end-November 2025) and EC adoption process; prepare for voluntary uptake in 2026 reporting cycles
- Listed companies
- Conduct or update materiality assessments per EFRAG guidance (e
- Prepare xHTML digital tagging for sustainability statements in management reports
- French firms
Key Dates
July 31, 2025 - EFRAG publishes draft simplified ESRS for public consultation.
September 29, 2025 - Consultation closes.
End of November 2025 - EFRAG submits technical advice to European Commission.
2026 financial year (reports in 2027) - Voluntary application of simplified standards, if legislative timeline allows.
2027 (reports in 2028) - Full mandatory application targeted.
Compliance Impact
Urgency: Medium - Not immediate mandates, as this is a consultation response with voluntary 2026 start, but proactive preparation is essential for large listed firms facing AMF scrutiny on 2025/2026 statements. Matters due to potential burden reduction (57% fewer datapoints) balanced by AMF's push f
Asset ManagerBankAll Firms
Crypto-assets Innovation The ACPR and AMF publish the summary of responses to the consultation conducted by the Working Group on Smart Contract Certification
The ACPR and AMF have published a summary of responses to a public consultation on a 2024 Working Group report exploring smart contract certification in DeFi, addressing technical standards, audit practices, and potential regulatory frameworks. This matters for compliance as it signals preparatory steps toward possible EU-level DeFi regulation, emphasizing risk reduction and trust-building without immediate mandates, influencing future operational and audit strategies for crypto firms.
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What Changed
No binding regulatory changes are introduced; this is an exploratory summary confirming industry support for proposed principles on technical standards (security, governance, compliance), audit methods (third-party, self-certification), and regulatory avenues (preference for voluntary certification over mandatory). Respondents endorsed alignment with industry best practices, risk-based approaches, and proportionality, with calls for technologically neutral standards and continuous monitoring mod
What You Need To Do
- Monitor developments
- Review internal practices
- Enhance documentation
- Engage stakeholders
Key Dates
2024 - Working Group conducts analysis and drafts report on smart contract certification.
3 February 2025 - Report published for public consultation.
14 March 2025 - Industry responses submitted (e.g., GDF, Adan).
16 July 2025 - Summary of consultation responses published by ACPR and AMF.
Compliance Impact
Urgency: Medium – This is not enforceable yet but previews potential mandatory certification in EU DeFi regulation, critical for firms scaling smart contract use to mitigate user risks and build trust; proactive alignment now avoids future retrofits, especially with MiCA's crypto focus.
Crypto ExchangeFintechAll Firms
Financial disclosures & corporate financing Journalists Listed companies and issuers The AMF orders DANAE GROUP to file a draft takeover bid for ENTREPRENDRE shares
The AMF has ordered Danae Group to file a draft takeover bid for shares in Entreprendre, enforcing mandatory public offer rules triggered by a shareholding threshold crossing. This matters for compliance professionals as it exemplifies AMF's strict oversight of takeover regulations, ensuring market integrity, equal treatment of shareholders, and timely disclosures in listed company transactions. It underscores the risks of non-compliance, potentially leading to enforcement actions.
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What Changed
No new regulatory changes are introduced; this is an enforcement decision applying existing AMF rules on mandatory takeover bids under the General Regulation (RGAMF), particularly Articles 234-2 et seq. Key requirements include: filing a draft offer with the AMF for compliance review within 10 trading days; mandatory cash offers at the highest price paid by the offeror (alone or in concert) in the prior 12 months; adherence to principles of free play of bids, equal treatment, transparency, marke
What You Need To Do
- File draft takeover bid immediately
- Appoint independent appraiser
- Inform AMF and publish
- Prepare target response
- Monitor thresholds
Key Dates
Within 4-6 weeks of triggering event - Danae Group must file draft takeover bid (practice standard; exact trigger date not specified in publication). DEADLINE
10 trading days from offer period start - AMF reviews draft for compliance and issues visa (extendable if appraiser or works council involved, min. 5 trading days post-target reply). DEADLINE
Pre-offer period (post-announcement) - Strict trading rules apply; offeror may acquire shares until opening, with restrictions.
Offer period - From AMF filing notice to results publication; minimum success threshold 50% (waivable by AMF).
Compliance Impact
Urgency: High - Immediate filing obligation for Danae Group risks escalation to sanctions if ignored; for others, it signals AMF's proactive enforcement, heightening scrutiny on share acquisitions in listed firms. Matters due to potential market disruption, shareholder protection mandates, and prece
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Market infrastructures Innovation Europe & international Cooperation Other professionals Market Infrastructures Journalists Investment management companies The French and Italian authorities make proposals for a more competitive...
The French (AMF) and Italian (Consob) financial authorities have jointly proposed amendments to the EU's DLT Pilot Regime to increase its competitiveness and attract market participants. The Pilot Regime, which became operational in March 2023, has underperformed with only three authorized infrastructures and minimal live trading activity, prompting regulators to recommend structural changes including greater proportionality, expanded eligible instruments, and raised activity thresholds.
What Changed
The proposed amendments address the Pilot Regime's limited uptake by introducing the following regulatory modifications:
*Scope Expansion
Expand eligible financial instruments from current restrictions to all financial assets**
Remove categorical limitations that previously restricted participation
*Activity Thresholds
Raise activity thresholds from €6 billion to €100 billion
Introduce greater proportionality based on project scale**, allowing smaller players simplified requirements
*Operatio
What You Need To Do
- *For Market Infrastructure Operators
- *Reassess Business Cases
- *Prepare Applications
- *Monitor Commission Decisions
- *Compliance Documentation
Key Dates
March 24, 2026 - ESMA report deadline to European Commission on Pilot Regime functioning and recommendations DEADLINE
June 30, 2026 - End of MiCA transitional period; full crypto-asset regime implementation
Q2 2026 - Expected European Commission report to Parliament and Council with recommendations on Pilot Regime extension, amendment, or permanent conversion
April 9, 2025 - AMF and Consob formal proposals submitted
Mid-2022 - Original DLT Pilot Regime legislation enacted
Compliance Impact
Urgency: HIGH
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Anti-money Laundering Asset management AMF invites financial market participants to take part in the EBA consultation on draft AML/CFT implementing standards
The AMF is urging French financial market participants to engage in the EBA's consultation launched on March 6, 2025, on draft Regulatory Technical Standards (RTS) for AML/CFT implementing standards under AMLD6 and AMLR, focusing on harmonized risk assessment methodologies for supervisors and obliged entities. This matters because it signals a shift to uniform EU-wide AML/CFT supervision via AMLA (post-EBA handover on January 1, 2026), requiring firms to adapt to standardized risk indicators, data reporting, and enforcement, with new CDD rules applying from July 2027. Participation ensures firms influence final standards amid the transition to a single EU AML rulebook.
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What Changed
The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control effectiveness (governance, policies, procedures, group supervision), and residual risk; annual reviews and ad-hoc reassessments; standardized scoring for consistent EU supervision.
Risk Assessment for Direct Supervision (Article
What You Need To Do
- Participate in EBA consultation
- Conduct compliance gap analysis
- Enhance systems
- Prepare for AMLA supervision
- Ongoing monitoring
Key Dates
March 6, 2025 - EBA consultation launch on draft RTS for AML/CFT standards (ongoing as of analysis).
January 1, 2026 - EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA ; existing EBA guidelines remain until replaced.
July 10, 2027 - New AMLD6/AMLR rules apply directly , including CDD for new customers and start of phased compliance. DEADLINE
By July 2032 - Full CDD compliance for existing customers (five-year transition from 2027).
2028 - AMLA begins direct supervision of selected high-risk entities.
Compliance Impact
Urgency: High – While not yet final, the consultation shapes binding RTS under the new AMLA-led regime post-January 2026 handover, with direct rules from July 2027 requiring system upgrades and data readiness; delays risk non-compliance with harmonized supervision, higher sanctions, and AMLA scrutin
Asset ManagerBankAll Firms
Crypto-assets Innovation The ACPR and the AMF publish the findings from the Working Group on Smart Contract Certification, and launch a Public Consultation
The ACPR and AMF have published findings from their 2024 Working Group on Smart Contract Certification in DeFi, launching a public consultation on February 3, 2025, to explore certification frameworks for smart contracts, focusing on standards, audits, and regulatory options. This matters as it signals proactive French regulatory preparation for potential EU-level DeFi rules under MiCA, aiming to enhance security, governance, and compliance without immediate mandates, while industry feedback favors voluntary schemes.
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What Changed
No binding regulatory changes yet; this is exploratory work anticipating future regulation. The report proposes:
Standards for security, governance, and compliance across execution environments.
Audit frameworks including public authority, third-party auditors, or self-certification.
Regulatory avenues from voluntary certification to obligations, with proportionate approaches.
Consultation responses (summarized post-March 2025) confirmed support for technical standards and audits but preferred v
What You Need To Do
- Participate/Review
- Assess Smart Contracts
- Monitor Developments
- Engage Stakeholders
Key Dates
February 3, 2025 - Working Group report published and public consultation launched.
March 10, 2025 - Public consultation closed (per some reports; responses summarized afterward).
July 16, 2025 - ACPR/AMF published summary of consultation responses.
2025 (TBD) - Conclusions from consultation responses to be presented.
July 2026 - DASP regime fully phased out under MiCA transitional period.
Compliance Impact
Urgency: Medium. This is non-binding exploratory work with consultation closed, but it foreshadows potential mandatory smart contract certification in DeFi, aligning with MiCA's risk mitigation goals. Firms face low short-term risk but high long-term impact if voluntary standards evolve into obligat
Crypto ExchangeFintechBank
Crypto-assets Innovation The AMF publishes the summary of responses received to its Discussion Paper on Decentralised Finance
The Autorité des Marchés Financiers (AMF) has published a summary of stakeholder responses to its June 2023 Discussion Paper on Decentralised Finance (DeFi), analyzing regulatory challenges posed by automated, decentralized crypto-asset activities. This matters for compliance professionals as it signals the AMF's ongoing commitment to developing a balanced DeFi framework amid MiCA's implementation, potentially shaping future supervision of decentralized protocols while emphasizing investor protection and innovation.
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What Changed
No immediate regulatory changes or new requirements are introduced; this is a non-binding summary of consultation feedback from July 2024, intended to inform future discussions rather than enact rules. It highlights stakeholder views on DeFi's challenges, such as decentralization's impact on traditional oversight, with the AMF planning continued ecosystem engagement to outline proportionate responses. Related updates include clarifications on DASP transitions to MiCA CASP licensing (e.g., abolit
What You Need To Do
- Monitor and engage
- MiCA compliance
- Assess decentralization
- Update policies
Key Dates
June 2023 - AMF publishes initial Discussion Paper on DeFi regulatory challenges.
July 2024 - AMF publishes summary of responses to DeFi Discussion Paper.
December 30, 2024 - MiCA enters force for CASPs.
June 30, 2026 - End of MiCA transitional period for DASPs; full CASP licensing required. DEADLINE
July 2027 - EU AMLR ("single rulebook") comes into effect, standardizing crypto due diligence. DEADLINE
Compliance Impact
Urgency: Medium - This consultation summary does not impose new obligations but underscores evolving DeFi scrutiny within MiCA's firm deadlines (e.g., June 2026 transition end), making it critical for crypto firms to align now to avoid sanctions like DASP withdrawals. It matters for maintaining comp
Crypto ExchangeFintechAsset Manager
Innovation Markets Decentralised Finance (DeFi): IOSCO publishes its consultation report
The AMF publication announces IOSCO's consultation report on Decentralised Finance (DeFi), highlighting ongoing global efforts to regulate DeFi activities under IOSCO's 2023 policy recommendations. This matters for compliance professionals as it signals intensifying scrutiny on DeFi platforms for investor protection, market integrity, and financial stability risks, potentially leading to harmonized rules that bridge traditional finance and crypto assets. Firms involved in DeFi must monitor this to align with emerging "same risk, same rule" standards across jurisdictions.
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What Changed
No immediate binding regulatory changes are introduced, as this is a consultation report tied to IOSCO's 2023 DeFi Recommendations and a 2025 Thematic Review assessing implementation progress. Key focuses include enhanced regulatory cooperation (Recommendation 11), addressing gaps in enforcement for Crypto Asset Service Providers (CASPs), and applying CDA Policy Recommendations to DeFi for risks like financial stability, investor protection, and market integrity. Progress is noted in legal frame
What You Need To Do
- Review and comment
- Gap analysis
- Enhance compliance
- Monitor cross-border
- Pilot participation
Key Dates
31 July 2025 - Cut-off date for assessing Participating Jurisdictions' regulatory frameworks in IOSCO's Thematic Review.
October 16, 2025 - Publication date of FSB and IOSCO reports assessing crypto-asset and stablecoin implementation, including DeFi elements.
2 February 2026 - IOSCO consultation comment deadline on related reports (e.g., FMIs’ management of general business risks). DEADLINE
6 February 2026 - CPMI-IOSCO consultation comment deadline on FMIs’ general business risks guidance, relevant to DeFi infrastructure. DEADLINE
starting 2026 .
Compliance Impact
Urgency: High – While not yet binding, the report underscores incomplete global implementation (e.g., enforcement gaps, regulatory arbitrage risks), with IOSCO/FSB calling for swift action amid 2025-2026 reviews. This matters as DeFi's growth amplifies systemic risks, prompting "same risk, same rule
Asset ManagerCrypto ExchangeFintech Periodic & ongoing disclosures Sustainable Finance Regulatory developments The AMF responds to the European Commission’s public consultation on the draft European sustainability reporting standards
The AMF's response to the European Commission's public consultation advocates for simplified European Sustainability Reporting Standards (ESRS) under the CSRD, emphasizing retained quality in climate reporting, interoperability with ISSB standards, and proportionality while opposing overly complex materiality assessments. This matters for compliance professionals as it signals upcoming ESRS revisions that could reduce reporting burdens but maintain investor-focused disclosures, influencing 2026-2028 sustainability statements for listed firms and financial institutions. https://www.amf-france.org/en/news-publications/news/amf-responds-european-commissions-public-consultation-draft-european-sustainability-reporting
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What Changed
Simplified ESRS Structure: EFRAG's draft reduces mandatory datapoints by 57-71% and ESRS length by 55%, focusing on materiality, fair presentation, and quantitative data while streamlining double materiality assessments and eliminating sector-specific standards. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european ; https://www.iss-corporate.com/resources/blog/eu-sustainability-rules-reset-what-the-2026-
What You Need To Do
- Review and refresh double materiality assessments using "gross" impacts, specifying risks/opportunities per topic
- Retain "net-zero" definitions in climate plans if used; prepare quantitative climate financial effects data (Option 1)
- Evaluate "undue costs" reliefs for non-climate metrics, documenting with time-bound justifications
- Monitor EFRAG/EC updates post-November 2025; test voluntary simplified ESRS in 2026 cycles
- Align with ESMA 2025 priorities (e
Key Dates
July 31, 2025 EFRAG submits simplified ESRS draft for consultation. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
September 29, 2025 EFRAG consultation closes. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
End of November 2025 EFRAG presents technical advice to European Commission. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
2026 Financial Year (reports in 2027) Voluntary use of simplified standards possible if legislative timeline allows. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european ; https://www.amf-france.org/en/news-publications/depth/csrd-sustainability-reporting
2027 (reports in 2028) Full mandatory application targeted. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
Compliance Impact
Urgency: Medium – Revisions offer relief (e.g., 57%+ datapoint cuts) but require proactive preparation for voluntary 2026 use and mandatory 2027/2028; critical for 2025 reporters under current ESRS/"quick fix" to avoid enforcement. Matters due to AMF/ESMA supervision ramp-up, investor demands for co
Asset ManagerBankAll Firms
Crypto-assets Innovation Fintech Journalists The AMF publishes a discussion paper on Decentralised Finance (DeFi)
The Autorité des Marchés Financiers (AMF), France's financial markets regulator, published a discussion paper on June 19, 2023, outlining preliminary thoughts on regulatory challenges posed by Decentralised Finance (DeFi) activities on crypto-assets, inviting stakeholder feedback by September 30, 2023. A summary of responses was released on July 10, 2024, highlighting key themes like defining DeFi, distinguishing protocol types, and applying a "same activity, same risk, same regulation" principle. This matters for compliance professionals as it signals AMF's intent to develop proportionate DeFi oversight, balancing innovation with investor protection, AML/CTF risks, and market integrity amid evolving EU frameworks like MiCA.
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What Changed
This is a discussion paper and consultation, not binding legislation, so no immediate regulatory changes or requirements are imposed. Key discussion points include:
Defining DeFi based on decentralization criteria (e.g., automation, network architecture, governance, lack of single points of failure).
Distinguishing permissioned vs. permissionless protocols and public vs. private blockchains.
Regulatory approaches to smart contracts (e.g., certification, varying responsibilities), open-source cod
What You Need To Do
- Submit feedback (past deadline)
- Monitor developments
- Conduct internal assessments
- Enhance compliance programs
- Engage stakeholders
Key Dates
June 19, 2023 - AMF publishes initial discussion paper on DeFi regulatory issues.
September 30, 2023 - Deadline for stakeholder contributions to the discussion paper. DEADLINE
July 10, 2024 - AMF publishes summary of responses to the discussion paper.
Compliance Impact
Urgency: Medium – This is non-binding consultation feedback without hard deadlines or rules, but it previews AMF's regulatory trajectory toward DeFi oversight, including AML/CTF enforcement and investor safeguards, amid MiCA rollout. It matters because DeFi's growth amplifies risks like pseudonymity
FintechCrypto ExchangeAll Firms
Collective investments Shares The AMF presents its proposals to improve the readability of financial product fees in European law
The Autorité des Marchés Financiers (AMF, France's financial markets authority) has proposed a new table for presenting subscription fees on financial instruments and an accompanying glossary to enhance investor readability and comparability, developed in collaboration with the Financial Sector Consultative Committee (FSCC) as input to the European Commission's Retail Investment Strategy. This matters because it targets reconciling MiFID 2 and PRIIPs disclosure requirements, which currently hinder clear fee communication, potentially influencing future EU-level amendments to improve retail investor protection without imposing new obligations.
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What Changed
Alternative Fee Presentation Table: A proposed redesigned table for displaying costs associated with subscribing to financial instruments, emphasizing investor understanding rather than adding a new document; this requires evolving MiFID 2 regulations as current MiFID 2 and PRIIPs rules are incompatible for such clarity.
Glossary of Terms: A harmonized glossary defining key fee types, tested with non-professional investors using AMF consumer testing tools, to standardize terminology across profe
What You Need To Do
- Monitor and Respond
- Internal Review
- Testing and Training
- No immediate obligations, as this is a non-binding proposal requiring EU law changes
Compliance Impact
Urgency: Medium – This is a consultative proposal without firm deadlines or binding rules, but it signals likely EU-level shifts in fee disclosure under MiFID 2/PRIIPs, impacting retail investor-facing firms. It matters for proactive compliance, as early adoption of clearer formats could mitigate fu
Asset ManagerWealth ManagerBroker Dealer Innovation The AMF publishes its proposals for an open finance framework
The Autorité des Marchés Financiers (AMF), France's financial markets authority, has published proposals for an **open finance framework** via a public consultation, extending open banking principles to broader financial data sharing for enhanced innovation and competition. This matters for compliance professionals as it signals upcoming regulatory requirements for secure data access, APIs, and customer consent mechanisms, aligning with EU trends toward open finance while prioritizing consumer protection and market resilience. Firms must engage early to shape the final rules and prepare systems for compliance.
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What Changed
The publication outlines AMF's proposals for an open finance framework, building on open banking (e.g., PSD2) to include investments, insurance, and asset management data. Key elements include:
Mandatory API-based data sharing for account information and payment initiation, extended to non-banking products like securities and insurance.
Enhanced customer consent and control mechanisms, with granular permissions, revocation rights, and strong authentication.
Security and liability standards align
What You Need To Do
- Review and respond to consultation
- Conduct gap analysis
- Update policies
- Engage stakeholders
- Test systems
Key Dates
January 14, 2026 - AMF publishes 2026 priorities, including open finance as part of innovation framework.
TBD (consultation period) - Public consultation on open finance proposals; firms should check AMF site for exact submission deadline (typically 1-3 months post-publication). DEADLINE
June 30, 2026 - End of MiCA transitional period, relevant for crypto/open finance intersections.
2026 (H2) - Expected finalization of AMF AI roadmap and tokenization consultation, influencing open finance APIs.
likely 2027 implementation phased over 12-24 months.
Compliance Impact
Urgency: High – As a consultation, immediate engagement is critical to shape rules, but full implementation may not hit until 2027+. It matters due to alignment with AMF's 2026 priorities on innovation (AI, tokenization, MiCA) and resilience (DORA, cybersecurity), risking fines or supervisory action
BankAsset ManagerFintech
Governance Europe & international The AMF encourages French participants to provide feedback to ESMA’s call for evidence on the implementation of the Shareholders Rights Directive (SRD 2)
The AMF publication urges French market participants to submit feedback to ESMA's call for evidence evaluating the implementation of the Shareholder Rights Directive II (SRD II), which aims to enhance long-term shareholder engagement, transparency in voting processes, and issuer-shareholder dialogue across the EU/EEA. This matters for compliance teams as it signals ongoing regulatory scrutiny of SRD II transposition and operational compliance, potentially leading to harmonized amendments that could require process updates in shareholder identification, voting transmission, and engagement disclosures. French firms' input can influence future EU rules, mitigating risks of non-compliance with evolving standards.
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What Changed
This AMF notice itself introduces no new regulatory changes; it promotes participation in ESMA's review of SRD II (Directive (EU) 2017/828), implemented via national laws by June 2019 and effective from September 3, 2020. SRD II's core requirements include: shareholder identification without delay, electronic/machine-readable transmission of voting and meeting information along the intermediary chain, confirmation of vote recording/counting, transparency on institutional investor and asset manag
What You Need To Do
- Submit feedback to ESMA
- Review current compliance
- Enhance processes if needed
- Monitor ESMA/EC outputs
Key Dates
June 10, 2019 - EU Member States' transposition deadline for SRD II into national law (e.g., France via law of May 22, 2019). DEADLINE
September 3, 2020 - SRD II go-live date for operational requirements like shareholder identification and voting processes.
October 3, 2022 - European Commission request to ESMA/EBA for SRD II input, contextualizing ESMA's ongoing review.
of 2026 .)
Compliance Impact
Urgency: Medium - SRD II has been live since 2020, so core compliance is established, but ESMA's review could trigger targeted amendments (e.g., operational standardization), especially for French intermediaries handling cross-border flows. This matters for avoiding supervisory findings in ongoing A
Asset ManagerBroker DealerBank
AMF activity AMF Chair: Proposal to appoint Marie-Anne Barbat-Layani
This AMF publication announces a proposal to appoint Marie-Anne Barbat-Layani as Chair of the AMF, France's financial markets authority responsible for investor protection, market supervision, and regulatory enforcement. It matters for compliance professionals because leadership changes at key regulators like the AMF can signal shifts in enforcement priorities, supervisory focus, or policy directions affecting investment firms, asset managers, and market participants across the EU. While not imposing immediate rules, it warrants monitoring for potential impacts on ongoing consultations and governance expectations.
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What Changed
No specific regulatory changes or new requirements are outlined in this publication, as it solely concerns a leadership appointment proposal rather than substantive rule amendments. The AMF's standard process for such proposals involves board review and government ratification, but no alterations to the General Regulation, policies, or compliance obligations are proposed here.
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What You Need To Do
- binding appointment proposal without compliance obligations
- Monitor AMF website (https
- Review existing AMF relationships and prepare for potential shifts in supervisory engagement
- Update internal governance logs noting key regulator personnel changes
Compliance Impact
Urgency: Low – This is a procedural leadership announcement with no immediate regulatory or operational impacts. It matters for long-term strategic planning, as the new Chair could influence AMF's approach to MiFID II implementation, sustainability integration, or enforcement, but firms face no urge
Asset ManagerBroker DealerBank 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
Asset ManagerWealth Manager
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
Asset ManagerBankAll Firms
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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Asset management Regulatory developments Other professionals Journalists Investment services providers Investment management companies The AMF launches a consultation on the integration of sustainability requirements into its General Regulation
The AMF has launched a public consultation to integrate sustainability requirements into its General Regulation, aiming to embed ESG considerations directly into core operational rules for regulated entities. This matters for compliance professionals as it signals a shift toward mandatory sustainability integration across asset management and investment services, aligning with EU frameworks like SFDR and CSRD, and potentially increasing reporting and risk management obligations.
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What Changed
Integration of sustainability risks: The updated General Regulation requires asset management companies to explicitly take sustainability risks into account when complying with existing requirements (e.g., paragraphs 6-9 on governance and operations), marking a formal embedding of ESG into the AMF's foundational rulebook.
Alignment with EU sustainability frameworks: Builds on SFDR revisions by advocating for minimum environmental criteria in Article 8/9 products, simplification of rules, and sup
What You Need To Do
- Participate in consultation
- Review and update policies
- Fund name compliance
- Enhance reporting
- Monitor EU developments
Key Dates
21 November 2024 - Application date for ESMA Guidelines on ESG fund names (new funds).
21 May 2025 - Application date for ESMA Guidelines on ESG fund names (existing funds).
30 December 2024 - AMF ESG Doctrine updated to comply with ESMA Guidelines.
30 June 2026 - General Regulation of the AMF enters into force, including sustainability risk integration.
January 13, 2026 - Referenced date for public consultation on General Regulation changes (exact consultation close date not specified in available data).
Compliance Impact
Urgency: High - While the General Regulation effective date is 30 June 2026, related ESG rules (e.g., fund names) are already applicable, and consultation input is time-sensitive. This matters due to escalating EU sustainable finance enforcement, greenwashing risks, and operational overhauls require
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Europe & international Sustainable Finance Asset management The AMF invites providers, users and rated entities to respond to ESMA's Call for evidence on the ESG rating market in Europe
The AMF is urging French stakeholders—ESG rating providers, users, and rated entities—to respond to ESMA's 2022 Call for Evidence on the EU ESG rating market to inform European Commission efforts on improving transparency and reliability. This matters as it contributes to the foundational data driving the ESG Ratings Regulation (EU 2024/3005), which imposes authorization, disclosure, and conflict-of-interest rules on providers, affecting sustainable finance compliance across the EU. With the regulation applying from 2 July 2026, early engagement helps shape final rules amid ongoing ESMA consultations on technical standards.
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What Changed
This AMF notice itself introduces no new regulatory changes; it promotes responses to ESMA's 2022 Call for Evidence, which gathered market insights to support the European Commission's July 2021 sustainable finance strategy. However, it highlights the push for a European framework on ESG ratings, including transparency on methodologies, conflict-of-interest management, internal controls, and dialogue with rated companies—elements now codified in the ESG Ratings Regulation effective 2 January 202
What You Need To Do
- For ESG Providers
- For Users and Rated Entities
- All Affected Firms
- AMF Stakeholders
Compliance Impact
Urgency: High – The 2022 Call for Evidence is historical, but it feeds into the ESG Ratings Regulation now in force (since 2 January 2025), with application looming on 2 July 2026—less than 6 months away as of January 2026. Firms face authorization risks, operational overhauls for conflicts/disclosu
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