Markets Europe & international Cooperation FMSB signs Consultation Agreement with Autorité des Marchés Financiers
The Autorité des Marchés Financiers (AMF) and Financial Markets Standards Board (FMSB) have signed a Consultation Agreement to enhance collaboration on developing guidance for wholesale Fixed Income, Currencies, and Commodities (FICC) markets, allowing AMF to provide expertise on FMSB drafts. This matters for compliance professionals as it signals regulatory endorsement of FMSB's non-binding standards, potentially elevating their influence on market conduct expectations in France and Europe, particularly as Paris grows as a trading hub. https://www.amf-france.org/en/news-publications/news/fmsb-signs-consultation-agreement-autorite-des-marches-financiers
What Changed
This is not a regulatory change imposing new rules but a bilateral Consultation Agreement outlining cooperation mechanisms. Key elements include: AMF input on FMSB's annual strategy refresh via discussions with FMSB Chair/CEO; annual high-level oral updates on FMSB strategy progress; operational updates on FMSB workplan/priorities; and AMF's ability to review and challenge draft FMSB guidance materials and publications for wholesale FICC markets. The agreement is non-binding, personal to the parties, and amendable only by mutual written consent, with no third-party rights.
Suggested Considerations
- Review and monitor FMSB's 2026 Workplan for upcoming Standards/Statements, noting AMF-influenced drafts (e.g., via FMSB committees and buy-side forum). https://fmsb.com/wp-content/uploads/2026/01/FMSB-2026-Workplan_Final.pdf
- Benchmark internal FICC practices against FMSB guidance, especially vulnerability areas like market structures or conduct.
- Engage with FMSB membership or working groups if applicable, to align with emerging standards endorsed by AMF.
- Track AMF/FMSB updates for Paris-specific FICC developments. https://fmsb.com/fmsbsignsconsultationagreementwithamf/
Key Dates
- Operational oral updates on FMSB workplan/priorities as needed. https://www.amf-france.org/sites/institutionnel/files/private/2026-03/fmsb-amf-accord-2026.pdf
- Agreement signed and announced, marking effective date of collaboration (today's date). https://www.amf-france.org/en/news-publications/news/fmsb-signs-consultation-agreement-autorite-des-marches-financiers
- FMSB provides high-level oral update to AMF on strategy progress
- FMSB Chair/CEO discusses strategy refresh with AMF for input
Compliance Impact
Urgency: Low - This agreement introduces no direct obligations, deadlines, or penalties; it fosters indirect influence via enhanced credibility of FMSB's voluntary standards in AMF-regulated markets. It matters for long-term conduct risk management in FICC, as firms ignoring FMSB guidance (now AMF-supported) may face heightened supervisory scrutiny, especially amid Paris's trading growth and AMF's 2026 priorities for resilient markets. https://zoominvest.fr/actualites/patrimoine/amf-des-priorites-2026-axees-sur-l-attractivite-l-innovation-et-la-securite-des-marches/iob24fnqfmfh258iwmxwwicy
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Broker DealerBank
Anti-money Laundering Asset management The AMF invites financial market participants to AMLA’s consultations on three draft AML/CFT implementing standards
The AMF is urging financial market participants, especially in asset management and related sectors, to engage in AMLA's public consultations on three draft Regulatory Technical Standards (RTS) under the new EU AML/CFT package, covering customer due diligence (CDD), identification of business relationships/transactions, and enforcement measures. These RTS aim to provide harmonized, proportionate implementation guidance, significantly impacting CDD processes and supervisory consistency across the EU, with underlying rules applying from 10 July 2027.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
What Changed
- - CDD RTS: Builds on EBA's prior draft with AMLA refinements for legal clarity, proportionality, and risk adaptation; specifies information/sources for identity verification of natural persons/legal...
- Business Relationships/Occasional/Linked Transactions RTS: Defines criteria under AMLR Article 19(9) to harmonize identification, ensuring consistent EU-wide application beyond basic...
- Enforcement RTS (Pecuniary Sanctions/Administrative Measures): Under AMLD6 Article 53(10), standardizes supervisor assessment/categorization of breaches for proportionate, effective, dissuasive...
Suggested Considerations
- Gap analysis and preparation: Assess current CDD/business identification/enforcement processes against drafts; identify changes for remote onboarding, PEPs, sectoral measures (e.g., asset manager Article 17 scenarios), and sanctions screening; set milestones for policy/system updates by July 2027.
- Engage hearings: Attend 24 March 2026 public hearing for CDD/business RTS.
- Monitor post-consultation: Track AMLA/EC adoption (expected Q1 2026 for some related RTS) and national implementations (e.g., CSSF data reporting).
Key Dates
- Consultations opened by AMLA on three draft RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
- Consultation closes on RTS for pecuniary sanctions/administrative measures
- Online public hearing on CDD and business relationships RTS
- Consultations close on CDD RTS and business relationships/linked transactions RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]
- AMLA submits final draft RTS to European Commission for adoption
Compliance Impact
Urgency: High - These RTS operationalize core AMLR/AMLD6 mandates with July 2027 applicability, demanding immediate consultation input to influence final rules and 18-month lead time for system/process overhauls (e.g., CDD verification sources, harmonized transaction linking). Failure to engage risks non-compliant frameworks amid AMLA's push for EU-wide consistency, elevated direct supervision risks, and stricter enforcement; asset managers face acute challenges from intermediary distribution rules.[Source URL:...
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Asset ManagerCrypto ExchangeAll Firms
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.
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);...
- Climate reporting: Regrets removal of "net zero" definition (90-95% gross GHG reduction trajectory), essential for 2024 comparability.
- Anticipated financial effects: Strongly backs Option 1 (quantitative info required, with exceptions) for climate matters to align with ISSB and investor needs; flexible for other topics.
- Reporting reliefs: Supports "undue costs/efforts" exemptions (e.g., metrics except Scope 3 GHG) with time-bound limits to match ISSB.
EFRAG's draft cuts mandatory datapoints by 57-61%, eliminates...
Suggested Considerations
- Monitor EFRAG's post-consultation technical advice (end-November 2025) and EC adoption process; prepare for voluntary uptake in 2026 reporting cycles.
- Listed companies: Refine materiality processes to specify IRO types and use gross impacts; retain "net zero" definitions in climate plans; prioritize quantitative climate financial effects.
- Conduct or update materiality assessments per EFRAG guidance (e.g., value chain, thresholds); leverage "undue costs" relief judiciously with time limits.
- Prepare xHTML digital tagging for sustainability statements in management reports.
- French firms: Align 2026 statements with AMF supervisory expectations, noting non-adoption of ESMA's GLESI guidelines pending full CSRD transposition.
Key Dates
- EFRAG publishes draft simplified ESRS for public consultation
- Consultation closes
- EFRAG submits technical advice to European Commission
- Sector-specific ESRS adoption planned
- Voluntary application of simplified standards, if legislative timeline allows
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 for investor-critical details like quantitative climate effects, aligning EU CSRD with global ISSB standards amid supervisory ramp-up.
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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.
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 models.
Suggested Considerations
- Monitor developments: Track ACPR/AMF Fintech Forum updates for potential voluntary certification pilots or EU harmonization under MiCA/pending DeFi rules.
- Review internal practices: Align smart contract governance, audits, and change management with endorsed principles (e.g., third-party audits, risk-based recertification on material changes).
- Enhance documentation: Prepare for possible protocol-level certification, including modular DeFi interactions and continuous on-chain monitoring.
- Engage stakeholders: Participate in future consultations via industry groups like GDF or Adan to influence voluntary frameworks.
Key Dates
- Working Group conducts analysis and drafts report on smart contract certification
- Report published for public consultation
- Industry responses submitted (e.g., GDF, Adan)
- 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.
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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.
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, market integrity, fairness, and competition.
Suggested Considerations
- File draft takeover bid immediately: Submit to AMF with price details (highest 12-month price, cash only), intent on squeeze-out, and supporting documents.
- Appoint independent appraiser: Mandatory if squeeze-out planned; fairness statement required.
- Inform AMF and publish: Disclose filing; adhere to trading restrictions during pre-offer/offer periods.
- Prepare target response: Entreprendre to file draft reply document, potentially involving works council.
- Monitor thresholds: Ongoing vigilance for 30% voting rights or 1% 12-month crossings by any party.
Key Dates
6 weeks of triggering event; - Danae Group must file draft takeover bid (practice standard; exact trigger date not specified in publication)
- AMF reviews draft for compliance and issues visa (extendable if appraiser or works council involved, min. 5 trading days post-target reply)
offer period (post-announcement); - Strict trading rules apply; offeror may acquire shares until opening, with restrictions
- 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 precedent for rapid intervention (e.g., visa timelines enforce orderly processes).
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All Firms
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
Operational Flexibility
Suggested Considerations
- *For Market Infrastructure Operators:
- *Reassess Business Cases: Evaluate viability under revised €100 billion thresholds and expanded instrument eligibility
- *Prepare Applications: Organizations previously excluded by €6 billion threshold should prepare authorization applications under new proportionality framework
- *Monitor Commission Decisions: Track European Commission's response to ESMA report (expected Q2 2026) for final regulatory direction
- *Compliance Documentation: Prepare operational and technical documentation demonstrating alignment with revised requirements
Key Dates
- Pilot Regime became operational
- AMF and Consob formal proposals submitted
- ESMA report deadline to European Commission on Pilot Regime functioning and recommendations
- Expected European Commission report to Parliament and Council with recommendations on Pilot Regime extension, amendment, or permanent conversion
- End of MiCA transitional period; full crypto-asset regime implementation
Compliance Impact
Urgency: HIGH
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Asset ManagerBroker DealerFintech
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.
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...
- Risk Assessment for Direct Supervision (Article 12(7) AMLAR): Two-stage selection for AMLA direct oversight of high-risk cross-border firms (operating in ≥6 Member States, meeting...
- CDD Updates: Risk-based approach for new customers from July 2027; five-year transition for existing customers, prioritizing high-risk.
- Pecuniary Sanctions RTS (Article 53(10) AMLD6): Structured classification of breaches, proportionate sanctions, and enforcement for serious/repeated/systematic infringements to ensure uniformity...
Suggested Considerations
- Participate in EBA consultation: Submit feedback on draft RTS via EBA channels, focusing on risk indicators, data frequency, and feasibility; AMF encourages French firms to act promptly.
- Conduct compliance gap analysis: Review current AML frameworks against proposed indicators (inherent risk, controls, residual risk); prioritize high-risk customers/products.
- Enhance systems: Invest in regtech for automated risk scoring, transaction monitoring, and data reporting to supervisors; update governance, policies, and CDD processes.
- Prepare for AMLA supervision: For cross-border firms, model group-wide risk profiles; develop remediation plans for breaches.
- Ongoing monitoring: Implement annual risk reviews and ad-hoc reassessments for business changes.
Key Dates
EBA consultation launch; on draft RTS for AML/CFT standards (ongoing as of analysis)
EBA hands over AML/CFT mandates, tools (e.g., EuReCa database), and functions to AMLA; ; existing EBA guidelines remain until replaced
New AMLD6/AMLR rules apply directly; , including CDD for new customers and start of phased compliance
AMLA begins direct supervision; of selected high-risk entities
Full CDD compliance; for existing customers (five-year transition from 2027)
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 scrutiny for large firms. Matters due to shift to uniform EU standards, ending national discretion and increasing reporting burdens—firms acting now can influence outcomes and future-proof via tech/governance investments.
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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.
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...
Suggested Considerations
- Participate/Review: DeFi/crypto firms should review the report and response summary; late participation may inform ongoing discussions (consultation closed).
- Assess Smart Contracts: Evaluate internal smart contracts against proposed standards (security, governance, compliance) and audit practices for voluntary adoption.
- Monitor Developments: Track ACPR/AMF updates and EU MiCA/DeFi harmonization; prepare for potential fast-track CASP licensing if using certified contracts.
- Engage Stakeholders: Join ACPR-AMF Fintech Forum dialogues; implement AML/CFT enhancements for smart contract risks, as AMF/ACPR assess ongoing compliance.
Key Dates
- Conclusions from consultation responses to be presented
- Working Group report published and public consultation launched
- Public consultation closed (per some reports; responses summarized afterward)
- ACPR/AMF published summary of consultation responses
- 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 obligations, especially amid DASP phase-out by July 2026 and EU harmonization needs; proactive adoption builds MiCA compliance edge.
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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.
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.
Suggested Considerations
- Monitor and engage: Participate in AMF's ongoing DeFi discussions and tokenization consultations for asset managers; no mandatory actions from this summary alone.
- MiCA compliance: DASPs must apply for CASP licenses or leverage exemptions (e.g., notify AMF with operational/AML details if regulated entities); ensure AML/CTF alignment with EBA/TFR "Travel Rule" extensions.
- Assess decentralization: DeFi protocols should evaluate if they qualify as "sufficiently decentralized" to evade DASP rules; traditional firms notify AMF before crypto services.
- Update policies: Incorporate AMF clarifications on DASP transitions (DOC-2019-23/24 updates) and prepare for 2026 priorities like DORA cybersecurity.
Key Dates
- AMF publishes initial Discussion Paper on DeFi regulatory challenges
- AMF publishes summary of responses to DeFi Discussion Paper
- MiCA enters force for CASPs
- End of MiCA transitional period for DASPs; full CASP licensing required
- EU AMLR ("single rulebook") comes into effect, standardizing crypto due diligence
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 competitiveness in France's innovation-friendly regime, especially with AMF's 2026 focus on MiCA convergence and tokenization.
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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.
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 frameworks, but challenges persist in cross-border cooperation and enforcement beyond CASPs.
Suggested Considerations
- Review and comment: Submit feedback on IOSCO consultations by early February 2026 to influence final guidance on DeFi risks.
- Gap analysis: Assess current operations against IOSCO's 10 Assessed Recommendations (e.g., market integrity, investor protection, cross-border cooperation) and FSB frameworks, noting reforms underway.
- Enhance compliance: Implement AML mechanisms for DeFi (e.g., on-chain identity attestations), improve cybersecurity, business continuity, and enforcement powers for CASPs.
- Monitor cross-border: Leverage IOSCO MMoU for cooperation and prepare for global CASP supervision.
- Pilot participation: Explore EU DLT Pilot Regime or similar sandboxes for compliant DeFi activities.
Key Dates
- Cut-off date for assessing Participating Jurisdictions' regulatory frameworks in IOSCO's Thematic Review
- Publication date of FSB and IOSCO reports assessing crypto-asset and stablecoin implementation, including DeFi elements
- IOSCO consultation comment deadline on related reports (e.g., FMIs’ management of general business risks)
- CPMI-IOSCO consultation comment deadline on FMIs’ general business risks guidance, relevant to DeFi infrastructure
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" enforcement; firms risk non-compliance fines, operational restrictions, or lost innovation opportunities without proactive alignment.
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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
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 Assessment: AMF opposes assessing impact materiality post-mitigation (prefers "gross" approach for relevance and consistency) but supports specifying impacts, risks, or opportunities per...
- Climate Reporting: AMF regrets removal of "net-zero" target definition (requiring 90-95% gross GHG reduction trajectory) and seeks harmonization for financial actors; supports Option 1 for...
- Reporting Reliefs: Introduces "undue costs or efforts" exemptions (e.g., for metrics except Scope 3 GHG), with AMF recommending time-bound limits; further simplification proposed for social metrics...
- Interoperability: AMF stresses alignment with ISSB, accepting some EU-specific divergences for simplification.
Suggested Considerations
- 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.
Key Dates
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
EFRAG consultation closes. https://www.amf-france.org/en/news-publications/news/corporate-sustainability-reporting-amfs-response-efrags-consultation-simplification-european
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
Potential ESRS adoption deadline. https://www.amf-france.org/en/news-publications/depth/csrd-sustainability-reporting
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
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 comparable climate data, and ISSB alignment risks if divergences grow.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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 code, and governance.
- Adopting IOSCO recommendations: identify responsible persons (developers, DAOs), enforce risk management, disclosures, conflict-of-interest mitigation, and applicable laws.
Suggested Considerations
- Submit feedback (past deadline): Stakeholders could contribute by September 30, 2023, to innovation@amf-france.org.
- Monitor developments: Track AMF/ACPR follow-ups, including smart contract certification discussions.
- Conduct internal assessments: Analyze DeFi exposures using IOSCO criteria—identify responsible persons, risks (operational, AML/CTF), interconnections with TradFi, and ensure disclosures/conflict management.
- Enhance compliance programs: Prepare for proportionate rules on governance, cybersecurity, solvency, transparency; align with "same risk, same regulation" for DeFi-like activities.
- Engage stakeholders: Participate in AMF ecosystem dialogues at French/EU/international levels.
Key Dates
- AMF publishes initial discussion paper on DeFi regulatory issues
- Deadline for stakeholder contributions to the discussion paper
- 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-driven financial crime and market abuse, potentially triggering enforcement of existing laws; firms risk non-compliance if unprepared for "same risk, same regulation" application, especially with AMF's international push.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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...
- Glossary of Terms: A harmonized glossary defining key fee types, tested with non-professional investors using AMF consumer testing tools, to standardize terminology across professionals and aid...
- No changes to fee calculation methodologies; focus is solely on presentation and terminology.
Suggested Considerations
- Monitor and Respond: Review the proposed table and draft glossary (available in French); consider submitting feedback via FSCC or directly to European Commission consultations on Retail Investment Strategy.
- Internal Review: Assess current MiFID 2/PRIIPs fee disclosures for compatibility with the proposed format; prepare for potential regulatory evolution by mapping existing presentations to the new table.
- Testing and Training: Evaluate glossary integration into client communications; conduct internal consumer testing aligned with AMF tools if adopting early.
- 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 future enforcement risks amid Retail Investment Strategy scrutiny, especially given AMF's history of fee doctrine updates (e.g., turnover fee bans).
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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 aligned with DORA (Digital Operational Resilience Act), including incident reporting and resilience testing.
- Governance structure with a centralized standards body, similar to open banking hubs in the UK or EU.
Suggested Considerations
- Review and respond to consultation: Submit feedback on proposals via AMF portal (https://www.amf-france.org/en/news-publications/news/amf-publishes-its-proposals-open-finance-framework) to influence final rules.
- Conduct gap analysis: Assess current APIs, data sharing capabilities, consent processes against proposed standards; integrate DORA compliance.
- Update policies: Revise customer onboarding, data protection (GDPR alignment), and TPP accreditation processes.
- Engage stakeholders: Participate in AMF's asset management tokenization consultation and AI use cases study for synergies.
- Test systems: Pilot secure APIs for investment/insurance data sharing; prepare for cybersecurity inspections.
Key Dates
- Expected finalization of AMF AI roadmap and tokenization consultation, influencing open finance APIs
- AMF publishes 2026 priorities, including open finance as part of innovation framework
- End of MiCA transitional period, relevant for crypto/open finance intersections
- Public consultation on open finance proposals; firms should check AMF site for exact submission deadline (typically 1-3 months post-publication)
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 actions for non-prepared firms amid EU harmonization push. Early movers gain competitive edge in data-driven services.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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 manager engagement policies/strategies, and extended scope to EEA-listed shares.
Suggested Considerations
- Submit feedback to ESMA: French participants must review ESMA's call for evidence and provide input on SRD II implementation challenges, such as intermediary processes, data transmission, and cross-border voting (immediate action urged by AMF).
- Review current compliance: Audit internal systems for SRD II adherence, including electronic formats (e.g., seev.008 messages, MT 260SRD mandates), vote confirmations, and engagement policy disclosures.
- Enhance processes if needed: Align with Implementing Regulation (EU) 2018/1212 for shareholder ID requests, meeting notifications, and voting (e.g., VOTACCESS adaptations for French market).
- Monitor ESMA/EC outputs: Prepare for potential rule changes from the review, such as harmonized documentation or deadlines.
Key Dates
- EU Member States' transposition deadline for SRD II into national law (e.g., France via law of May 22, 2019)
- SRD II go-live date for operational requirements like shareholder identification and voting processes
- European Commission request to ESMA/EBA for SRD II input, contextualizing ESMA's ongoing review
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 AMF/ESMA exams, as non-participation in feedback risks unaddressed pain points becoming enforceable rules; proactive input now supports influence over final outcomes.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
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.
Suggested Considerations
- binding appointment proposal without compliance obligations. Recommended steps include:
- Monitor AMF website (https://www.amf-france.org) for ratification confirmation and any inaugural statements on priorities.
- 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 urgent adjustments today.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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.
Suggested Considerations
- *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
- *Update promotional materials to include required warnings if materiality thresholds are met (managing/having managed at least one other retail PE fund and at least three funds that reached end-of-life)
- *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
Key Dates
- Revised ELTIF Regulation came into application
- Enactment of Attractiveness Law No. 2024-537 (establishing 15-year maximum lock-up period)
- AMF decision approving amendments to General Regulation
- Effective date for new Article 422-120-16 (bank details collection requirement for newly established funds)
- Publication in Official Journal of the French Republic
Compliance Impact
Urgency: HIGH
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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
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...
- 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 (e.g., Appendix B in S2) and an ISSB "Transition Resource Group" like IASB's for IFRS 9/15/17 to aid implementation.
- Double-materiality advocacy: Prefers standards addressing all stakeholders, not just investors.
No binding changes; ISSB issued final IFRS S1/S2 in June 2023.
Suggested Considerations
- Monitor and map standards: Conduct gap analyses between current disclosures, ESRS, and ISSB S1/S2, focusing on interoperability (e.g., climate metrics, Scope 3 GHG).
- Engage in transitions: Participate in potential ISSB Transition Resource Group or jurisdictional groups; prepare for phased ISSB implementation if adopted locally.
- Enhance reporting processes: Update materiality assessments for double-materiality, quantitative climate financial impacts, and ESG breadth; leverage AMF's 2025 study on listed firms for benchmarks.
- Stakeholder dialogue: Respond to ongoing consultations (e.g., EFRAG until Sep 2025) and track ISSB agenda priorities.
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 on French listed firms; low immediate enforcement but builds toward mandatory convergence.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
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
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.
- Proportionality in disclosures: Gradual implementation, prioritizing climate standards, balancing stakeholder needs with issuer costs, and ensuring SFDR coverage.
- Materiality focus: Enhanced guidance on materiality assessments, centering company-led analysis without presuming topics' materiality upfront.
- EU consistency: Avoid duplicating info from SFDR, Taxonomy, and other regs; rely on existing concepts.
Suggested Considerations
- Monitor ESRS evolution: Track EFRAG/EC updates on final standards, focusing on AMF priorities like materiality guidance and ISSB mapping.
- Enhance materiality processes: Develop/improve double materiality assessments, preparing guidance integration.
- Align reporting systems: Map ESRS to SFDR/Taxonomy data; test proportionality phased rollouts (e.g., climate first).
- Engage stakeholders: Participate in ongoing consultations (e.g., EFRAG connectivity); benchmark against ISSB for interoperability.
Key Dates
- 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
- 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
- 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
- Potential application of simplified ESRS (per EC quick fix hints). https://www.gibsondunn.com/efrag-releases-draft-simplified-european-sustainability-reporting-standards-esrs/
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 compliance, and avoiding EU fines (up to 10M EUR under CSRD).
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBankInsurance
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.
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...
- Alignment with EU sustainability frameworks: Builds on SFDR revisions by advocating for minimum environmental criteria in Article 8/9 products, simplification of rules, and support for CSRD...
- Anti-greenwashing measures: Complements recent AMF ESG Doctrine updates (effective 30 December 2024), enforcing ESMA Guidelines on fund names with ESG terms, such as 80% quantitative thresholds for...
Suggested Considerations
- Participate in consultation: Submit feedback on proposed sustainability integrations via AMF channels to influence final rules.
- Review and update policies: Conduct gap analysis against new sustainability risk requirements in General Regulation; integrate into governance, risk management, and investment processes ahead of 30 June 2026.
- Fund name compliance: For ESG-named funds, ensure 80% investments meet criteria, apply exclusions, and update marketing materials per AMF ESG Doctrine and ESMA Guidelines (immediate for new funds, by May 2025 for existing).
- Enhance reporting: Prepare double materiality assessments, digital xHTML filings for CSRD/ESRS, and SFDR-aligned disclosures; update client onboarding for sustainability preferences.
- Monitor EU developments: Track SFDR revisions, Taxonomy extensions, and ESMA digital taxonomy consultations.
Key Dates
- Application date for ESMA Guidelines on ESG fund names (new funds)
- AMF ESG Doctrine updated to comply with ESMA Guidelines
- Application date for ESMA Guidelines on ESG fund names (existing funds)
- Referenced date for public consultation on General Regulation changes (exact consultation close date not specified in available data)
- General Regulation of the AMF enters into force, including sustainability risk integration
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 required for investor protection and reporting accuracy, with non-compliance exposing firms to supervisory actions.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset Manager
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.
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 2025 (application from 2 July 2026).
Suggested Considerations
- For Users and Rated Entities: Although the 2022 Call for Evidence is closed, monitor ESMA's ongoing RTS consultations (closed 20 June 2025) and Commission feedback; assess internal ESG data reliance for SFDR/Taxonomy alignment and update policies for new disclosure requirements.
- All Affected Firms: Map ESG rating dependencies in investment processes, train compliance teams on upcoming rules, and engage in industry feedback to influence final RTS adoption expected post-Q4 2025.
- AMF Stakeholders: Although dated, the notice encouraged French market input; now pivot to compliance readiness for 2026 application.
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/disclosures, and potential market disruptions if unprepared; non-compliance could halt EU operations or trigger greenwashing probes under SFDR, amplifying sustainable finance scrutiny.
AI-generated analysis. May contain errors or omissions — verify with the
original AMF source
before acting. Full disclaimer.
Asset ManagerBankInsurance