Key dates
- 2026 (H2)
- - Expected finalization of AMF AI roadmap and tokenization consultation, influencing open finance APIs
- January 14, 2026
- - AMF publishes 2026 priorities, including open finance as part of innovation framework
- June 30, 2026
- - End of MiCA transitional period, relevant for crypto/open finance intersections
- TBD (consultation period) Deadline
- - Public consultation on open finance proposals; firms should check AMF site for exact submission deadline (typically 1-3 months post-publication)
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.
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.
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.