MMF Asset management Cooperation The AMF publishes its recommendations on the liquidity of Money Market Funds
AI Analysis
The AMF has finalized Recommendation DOC-2026-07 on money market fund liquidity, following its 8 June 2026 consultation and coordinated work with Ireland and Luxembourg. The recommendation introduces supervisory market-resilience reference levels above the binding MMFR minima: 20% weekly liquid assets (WLA) for VNAV MMFs and 40% for public debt CNAV and LVNAV MMFs, with notification and escalation expectations where breaches persist or are expected to be prolonged or significant.
Key dates
2026-06-08
The AMF launched its public consultation on the draft recommendation on MMF liquidity.
2026-10-30
The AMF published final Recommendation DOC-2026-07 on liquidity management for money market funds.
Suggested considerations
Consider mapping each affected MMF’s current and stressed WLA against both the applicable MMFR minimum and the AMF market-resilience reference level of 20% or 40%.
Consider documenting fund-specific liquidity calibration, including investor concentration, expected redemption patterns, dealing frequency, portfolio composition, currency exposure and market-liquidity assumptions, rather than relying only on a static WLA benchmark.
Consider reviewing liquidity-risk dashboards and escalation triggers so that a fall below the relevant resilience level is identified promptly and escalated through strengthened internal governance.
Consider establishing a documented process to determine when a breach has persisted for 10 business days and when a prolonged or significant deviation is reasonably anticipated.
Consider preparing an AMF notification package containing the duration and scale of the deviation, its causes, remedial measures, portfolio and investor-liquidity analysis, and relevant stress-test results.
Consider reviewing stress-testing scenarios and management information to ensure they support decisions to use or rebuild liquidity buffers without automatically activating liquidity-management tools solely because the resilience level is breached.
Consider confirming that policies distinguish the AMF supervisory resilience levels from the binding 15% and 30% MMFR WLA minima and identify the different consequences of each threshold.
Consider monitoring coordinated guidance from the Central Bank of Ireland, Luxembourg’s CSSF and the UK FCA because comparable 20% and 40% reference levels may affect cross-border group governance and supervisory expectations.
What changed
The AMF expects VNAV MMFs generally to maintain at least 20% WLA, compared with the 15% statutory minimum under Regulation (EU) 2017/1131 on money market funds (MMFR). Public debt CNAV and LVNAV MMFs are expected generally to maintain at least 40% WLA, compared with the 30% MMFR minimum. These are supervisory market-resilience levels rather than new statutory MMFR minimums. Where a fund falls sustainably below the relevant level, its management company is expected to apply heightened liquidity-risk vigilance, rapid escalation procedures and strengthened internal decision-making.
Compliance impact
The publication does not replace or increase the binding MMFR minimum WLA requirements of 15% for VNAV MMFs and 30% for public debt CNAV and LVNAV MMFs, but it creates clear supervisory expectations above those minima. Persistent or anticipated material breaches may lead to mandatory AMF notification, enhanced supervisory engagement and scrutiny of liquidity-risk governance, escalation and stress testing.
MiCA Regulatory developments Cooperation Europe & international Other professionals Fintech Investment services providers MiCA regulation revision: The French authorities publish their joint proposals
AI Analysis
On 2026-10-21, the French Treasury, AMF, Banque de France and ACPR submitted joint proposals to the European Commission's review of Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA). The submission is not binding and does not amend MiCA, but it signals likely French priorities for future legislation: clearer boundaries with MiFID and payment-services rules, stronger ESMA supervision of significant crypto firms, tighter treatment of non-compliant stablecoins, and a regulated framework for DeFi, staking and crypto lending.
Key dates
2026-10-21
The French Treasury, AMF, Banque de France and ACPR published their joint response to the European Commission consultation on the MiCA review.
2026-09-30 Deadline
The European Commission consultation deadline identified in independent legal commentary; this date had passed before publication of the French authorities' response.
Suggested considerations
Compliance teams may wish to maintain the existing MiCA control framework because this publication does not create an immediate amendment, authorisation requirement or prohibition.
Firms should consider mapping each token, service and distribution channel against the definitions and perimeter provisions of MiCA, MiFID II and payment-services legislation, with particular attention to products that could require more than one authorisation.
EU-authorised crypto-asset service providers should consider reviewing onboarding, asset-admission, execution, custody, trading and distribution controls for exposure to asset-referenced tokens or e-money tokens that may not satisfy MiCA requirements.
Stablecoin issuers and groups using the same fungible token across EU and third-country markets should consider documenting issuance structures, reserve segregation, redemption rights, equivalence assumptions and supervisory-cooperation dependencies in anticipation of possible multi-issuance rules.
Significant crypto-asset service providers and crypto-conglomerates should consider assessing governance, prudential, group-risk and supervisory-reporting readiness for a possible future shift of direct or enhanced oversight toward ESMA.
Banks, payment firms and investment firms should consider assessing strategic opportunities and regulatory dependencies arising from euro-denominated e-money tokens and tokenised bank deposits without treating the French position as approval of any specific product.
DeFi, staking and crypto-lending businesses should consider identifying responsible intermediaries, documenting due-diligence controls and preserving evidence of protocol governance and risk assessments pending any future EU framework.
Industry participants may wish to monitor the Commission's MiCA review, subsequent legislative proposals, ESMA and EBA opinions, and national implementation developments before changing operating models.
What changed
No legal requirements changed on 2026-10-21. The French authorities proposed streamlining MiCA and clarifying when an activity falls under MiCA, the legislation governing financial instruments, or payment-services legislation, including where one business model could require multiple authorisations. They stated that a financial instrument should remain fully subject to the financial-instruments regime irrespective of the technology used for issuance or trading, and that the same principle should apply to payment instruments.
Compliance impact
The immediate compliance impact is low because the publication is a non-binding consultation response, not a regulation, delegated act, supervisory decision or enforcement measure. Its strategic significance is material: the proposals could expand supervisory centralisation, increase scrutiny of non-compliant stablecoins and bring currently uncertain DeFi, staking and lending activities into more explicit conduct, due-diligence and responsibility frameworks if adopted.
Collective investments Asset management The Autorité des Marchés Financiers (AMF) has published a new instruction covering liquidity management procedures at OPCIs and evergreen FCPRs
AI Analysis
On 13 October 2026, the AMF published Instruction DOC-2026-05, introducing permanent liquid-asset cushion requirements and specified liquidity stress-testing expectations for OPCIs and open-ended evergreen FCPRs that are not authorised under the ELTIF Regulation. Existing funds established before that date receive a two-year transition period, while changes to redemption frequency or notice periods that affect the required cushion require prior AMF approval and specific investor notification.
Key dates
2026-10-13
Instruction DOC-2026-05 was published; it applies to the specified OPCIs and evergreen FCPRs, and the two-year transition period begins for funds established before this date.
2028-10-13 Deadline
End of the two-year transition period for OPCIs and evergreen FCPRs established before 2026-10-13. Management companies should have notified the AMF of compliance through ROSA and filed the prospectus or rules and required stress tests by this date.
Suggested considerations
Firms should identify every OPCI and evergreen FCPR in scope and map its redemption frequency, notice period, current liquid-asset holdings and applicable minimum cushion under Instruction DOC-2026-05.
Management companies should calculate whether each fund satisfies the applicable permanent cushion and assess whether the potentially reduced regime for funds marketed exclusively through eligible insurance or savings products is available and properly evidenced.
Compliance teams may wish to update prospectuses, evergreen FCPR rules and related investor disclosures to state the minimum liquid-asset cushion using the applicable Annex VII format.
Firms should produce or refresh liquidity stress tests using all scenarios specified in DOC-2026-05, including evidence that redemption requests can be met, and establish governance for periodic review and escalation of shortfalls.
Management companies should review whether any proposed change to redemption frequency or notice period would alter the required cushion and, if so, plan for prior AMF approval, specific investor notification and the applicable fee-free redemption right.
For funds existing on 2026-10-13, firms should plan the ROSA filing of the amended prospectus or rules and compliant stress tests before the end of the two-year transition period.
Product, distribution and insurance teams should verify that marketing materials and product documentation do not imply liquidity inconsistent with the fund’s redemption terms, liquid-asset cushion or stress-test assumptions.
Firms should monitor the forthcoming French transposition of Directive (EU) 2024/927 and assess whether subsequent statutory liquidity-management-tool requirements impose additional controls beyond DOC-2026-05.
What changed
The former authorisation approach, under which management companies generally demonstrated liquid assets equal to 30% to 40% of net assets and submitted stress tests, is replaced or formalised through a permanent liquidity cushion calibrated to the fund’s redemption frequency or redemption notice period. The AMF gives a monthly-redemption fund as an example requiring at least 25% of net assets in liquid assets.
Compliance impact
The publication creates concrete authorisation, documentation, investor-notification and liquidity-governance consequences for a specialised but potentially retail-linked segment of French alternative funds. Failure to maintain or disclose the required cushion, obtain prior approval for relevant redemption-term changes, or complete the ROSA compliance filing could prevent or delay authorisation and expose the management company and fund to supervisory challenge; future AIFMD amendments may add requirements.
Long term investment Shares The AMF publishes its response to the European Commission’s consultation on the review of the Shareholder Rights Directive (SRD)
AI Analysis
The AMF has submitted its response to the European Commission’s consultation on the review of the Shareholder Rights Directive (SRD), calling for stronger EU‑level harmonisation of shareholder rights, clearer rules on general meeting formats, and measures to support long‑term shareholder engagement. For compliance teams at listed issuers, intermediaries and custodians, this signals probable future changes to SRD II implementation that will affect general meeting organisation, shareholder identification and cross‑border voting processes across the EU.
Key dates
2007
– Original Shareholder Rights Directive (SRD I) adopted, establishing a basic EU framework for shareholder rights in listed companies
2017
– Revised Shareholder Rights Directive (SRD II) adopted, introducing measures to promote long‑term engagement, improve governance transparency and regulate exercise of shareholder rights, particularly at general meetings
20 July 2026
– AMF publishes its response to the European Commission’s consultation on the SRD review, setting out its expectations and proposals on harmonisation, meeting formats and shareholder engagement
Suggested considerations
Monitor the European Commission’s SRD review process closely, including the forthcoming legislative proposal and any related impact assessments, as these will determine concrete new obligations on meeting formats, shareholder identification and intermediaries’ duties.
Map current practices for general meetings (physical, hybrid, virtual‑only) against the AMF’s positions and SRD II requirements, and assess the extent to which existing procedures depend on national options or flexibilities that may be removed in a revised SRD.
For intermediaries and custodians, assess existing cross‑border voting, information transmission and shareholder identification processes to identify areas of fragmentation or reliance on local practices that may be affected by EU‑level harmonisation.
Engage with industry associations and local regulators to provide practical feedback on operational challenges (e.g. complex custody chains, vote confirmation, cut‑off times) so that future SRD revisions reflect realistic implementation constraints.
Update internal regulatory change logs and risk assessments to flag the SRD review as an emerging structural change to shareholder‑rights processes, with potential impacts on IT systems, contracts with intermediaries, and investor communications.
What changed
* The AMF advocates removal of many existing “Member State options” in SRD in order to achieve greater harmonisation of shareholder rights and issuer–shareholder interactions across the EU, reducing...
The AMF reiterates that long‑term shareholder engagement should remain a core objective of the revised SRD and that the framework should explicitly facilitate ongoing dialogue between issuers and...
The AMF supports the development of hybrid general meetings with real‑time remote voting as a structural feature of EU listed company governance, in line with the digitalisation of the economy and...
The AMF considers “closed‑door” general meetings (with no in‑person or remote shareholder participation) to be incompatible with SRD objectives and proposes that such formats be prohibited in the...
The AMF proposes that “virtual‑only” general meetings should remain possible but be subject to tighter regulation at EU level, including a requirement to obtain shareholders’ approval on a regular...
Compliance impact
Non‑compliance risks are currently indirect but likely to become significant once the SRD review translates into binding EU law, with potential enforcement by national competent authorities on meeting formats, shareholder information flows and voting processes. Firms that rely heavily on flexible national options or minimalist SRD II implementation will face higher remediation and operational change costs if they delay preparation.
MiCA Financial services providers Europe & international ESMA Public statement: ESMA calls on unauthorised crypto-asset service providers to wind down orderly, while also safeguarding clients’ interests, as MiCA transitional period ends
Why this matters
ESMA public statement establishing mandatory wind-down requirements for unauthorised crypto-asset service providers (CASPs) following MiCA transitional period end on 1 July 2026.
MiCA Crypto-assets Financial products Marketing Journalists Investment management companies Listed companies and issuers The AMF adapts its policy on complex financial products in response to the rise of crypto-assets
Why this matters
This regulatory update from the AMF (French financial markets authority) relates to the adaptation of its policy on complex financial products in response to the rise of crypto-assets. This impacts crypto exchanges, asset managers, and fintech firms operating in the crypto/digital assets space.
Sustainable Finance MIFID Investment advice Long term investment Other professionals Journalists Investment services providers Investment management companies The ACPR and the AMF present their joint approach helping...
Why this matters
This regulatory update from the ACPR and AMF in France relates to the joint approach they are presenting to help professionals take into account clients' sustainability preferences when providing investment advice. This impacts investment management firms, wealth managers, and banks that provide investment services.
Sustainable Finance Periodic & ongoing disclosures Corporate sustainability reporting: AMF’s response to EFRAG’s consultation on the simplification of European standards
AI Analysis
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.
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
June 2026
- Sector-specific ESRS adoption planned
2026 financial year (reports in 2027)
- Voluntary application of simplified standards, if legislative timeline allows
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.
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...
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.
MiCA Crypto-assets Crypto-assets: the AMF clarifies its policy on DASPs authorised under the PACTE Law to take account of the transitional period and facilitate the transition to MiCA
Why this matters
This regulatory update from the AMF (Autorité des Marchés Financiers) in France clarifies its policy on Digital Asset Service Providers (DASPs) authorized under the PACTE Law, in light of the upcoming transition to the EU's MiCA regulation.
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...
AI Analysis
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.
Key dates
March 2023
- Pilot Regime became operational
April 9, 2025
- AMF and Consob formal proposals submitted
March 24, 2026 Deadline
- ESMA report deadline to European Commission on Pilot Regime functioning and recommendations
Q2 2026
- Expected European Commission report to Parliament and Council with recommendations on Pilot Regime extension, amendment, or permanent conversion
June 30, 2026
- End of MiCA transitional period; full crypto-asset regime implementation
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
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
Asset management The AMF updates its policy following its decision to comply with the ESMA guidelines on the names of ESG funds
Why this matters
This regulatory update from the AMF relates to changes in its policy on the naming of ESG funds, in order to comply with ESMA guidelines. This impacts investment management firms that offer ESG-focused funds.
Sustainable Finance Asset management The Autorité des Marchés Finances has decided to apply ESMA's Guidelines on funds' names
Why this matters
This regulatory update from the Autorité des Marchés Finances (AMF) relates to the application of ESMA's Guidelines on funds' names, which is relevant for investment management and wealth management firms that offer sustainable investment products.
Regulatory developments Post-trading infrastructures Market infrastructures Cooperation Journalists AMF and Banque de France call for a well-anticipated move to T+1 Settlement Cycle
Why this matters
This regulatory update from the AMF and Banque de France calls for a move to a T+1 settlement cycle, which will impact banking, capital markets, and investment management firms.
Asset management The AMF completes its policy on gates in master-feeder structures
Why this matters
This regulatory update from the AMF relates to policy changes on gates in master-feeder fund structures, which is relevant for investment managers and wealth managers.
Asset management Europe & international Journalists Investment management companies Austrian, French, Italian and Spanish financial market authorities give their key priorities for a macro-prudential approach to asset management
Why this matters
This regulatory update from European financial authorities focuses on their priorities for a macro-prudential approach to asset management, which impacts investment management firms, banks, and broker-dealers. Key topics include prudential requirements, ESG, and reporting/disclosure.
Sustainable Finance Financial products Asset management Europe & international Regulatory developments The AMF publishes, in a position paper, the key principles it believes should guide the SFDR review
Why this matters
This regulatory update from the AMF (French financial markets authority) provides guidance on the review of the Sustainable Finance Disclosure Regulation (SFDR), which is relevant for asset managers operating in Europe.
Asset management UCIT Collective investments The AMF updates its policy on disclosures by collective investment schemes incorporating non-financial methods
Why this matters
This regulatory update from the AMF focuses on disclosure requirements for collective investment schemes that incorporate non-financial methods, which is relevant for asset managers and wealth managers.
Asset management Requirements for investment committees and the affiliation of fund managers of asset management companies: the AMF updates its policy
Why this matters
This regulatory update from the AMF (French financial markets authority) focuses on requirements for investment committees and the affiliation of fund managers at asset management companies. It is relevant for asset managers and impacts their governance and licensing/authorization.
Marketing Savings protection Retail investors Professional investors Journalists The ACPR and AMF encourage financial institutions to continue their efforts to take account of the vulnerability of ageing clients
Why this matters
This regulatory update from the ACPR and AMF encourages financial institutions to consider the vulnerability of aging clients, which impacts consumer protection, operational resilience, and governance. It is relevant for banks, wealth managers, and the broader financial industry.
Collective investments Asset management The AMF updates its policy on the information to be provided by collective investment schemes incorporating non-financial approaches
Why this matters
This regulatory update from the AMF focuses on the information requirements for collective investment schemes that incorporate non-financial approaches, such as ESG factors.
Crypto-assets Innovation Market infrastructures Post-trading infrastructures Market infrastuctures on blockchain technology: adaptation of the French securities laws
Why this matters
This regulatory update from the AMF (French financial regulator) relates to the adaptation of French securities laws to accommodate blockchain-based market infrastructures. This is relevant for banks, fintechs, and crypto exchanges operating in the French capital markets and crypto asset space.
Crypto-assets Digital assets: the AMF amends its policy on DASPs to clarify the transition to "enhanced" DASP registration
Why this matters
This regulatory update from the AMF (Autorité des Marchés Financiers) in France amends its policy on Digital Asset Service Providers (DASPs) to clarify the transition to an 'enhanced' DASP registration regime.
Financial services providers Asset management Marketing European Crowdfunding Services Providers: the AMF publishes a position on marketing communications
Why this matters
This regulatory update from the AMF (French financial regulator) is focused on marketing communications for European Crowdfunding Service Providers, which are relevant for asset managers, broker-dealers, and fintech firms operating in the crowdfunding space.
Asset management Employee savings funds: the AMF amends its policy on the simplified integration of liquidity management tools
Why this matters
This regulatory update from the AMF (French financial markets authority) amends its policy on the simplified integration of liquidity management tools for employee savings funds, which are investment vehicles for employee retirement savings.
Sustainable Finance Publication by the Climate and Sustainable Finance Commission: climate resolutions
Why this matters
This regulatory update from the AMF's Climate and Sustainable Finance Commission relates to climate resolutions, which is relevant for banking, investment management, and wealth management firms from an ESG and disclosure perspective.
Asset management Extension of the preparation of a Key Information Document to all collective investments: the AMF updates its policy
Why this matters
This regulatory update from the AMF extends the requirement to prepare a Key Information Document to all collective investments, which impacts asset managers and wealth managers. It relates to consumer protection and disclosure requirements.
Crypto-assets Innovation Digital assets: the AMF strengthens its policy on DASPs in relation to good repute and skills and promotional communications
Why this matters
This regulatory update from the AMF strengthens its policy on digital asset service providers (DASPs) in relation to good repute, skills, and promotional communications.
Innovation The AMF publishes its proposals for an open finance framework
AI Analysis
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.
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.
Asset management The AMF is supplementing its policy on liquidity management tools
Why this matters
This regulatory update from the AMF relates to liquidity management tools for asset managers and wealth managers, which are important for prudential requirements and operational resilience.
Asset management AMF modifies its policy to facilitate the implementation by asset management companies of the Delegated Regulation of the SFDR
Why this matters
This regulatory update from the AMF modifies its policy to facilitate the implementation of the SFDR Delegated Regulation by asset management companies. This is relevant for investment management firms and relates to ESG/sustainability reporting and disclosure requirements.
Asset management The AMF updates its policy on management fees for collective investment undertakings (CIUs)
Why this matters
This regulatory update from the AMF focuses on changes to management fees for collective investment undertakings, which is relevant for asset managers and wealth managers. The updates relate to consumer protection and disclosure requirements.
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
AI Analysis
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
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.
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.
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.
Regulatory developments Europe & international Sustainable Finance Periodic & ongoing disclosures AMF's response to the EFRAG consultation on the draft European sustainability reporting standards
AI Analysis
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
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
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
Suggested considerations
Monitor ESRS evolution: Track EFRAG/EC updates on final standards, focusing on AMF priorities like materiality guidance and ISSB mapping.
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.
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.
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).
Crypto-assets Digital assets: the AMF updates its policy on DASPs
Why this matters
This regulatory update from the AMF focuses on updating its policy on digital asset service providers (DASPs), which are firms operating in the crypto and digital assets space.
Asset management The AMF updates its policy on funds with high fees
Why this matters
This regulatory update from the AMF focuses on funds with high fees, which impacts investment management and wealth management firms. It relates to consumer protection and disclosure requirements.
Market infrastructures Post-trading infrastructures Review of the central clearing framework in the EU: the AMF publishes a position paper
Why this matters
This regulatory update from the AMF discusses a review of the central clearing framework in the EU, which is relevant for banks, broker-dealers, and asset managers involved in capital markets and trading activities.
Asset management The AMF updates its policy on portfolio asset management company control systems and programmes of operations
Why this matters
This regulatory update from the AMF focuses on portfolio asset management company control systems and programmes of operations, which is relevant for investment management and wealth management firms. It covers operational resilience and authorization/licensing requirements.
Asset management Collective investments The AMF updates its policy on the marketing communications of collective investments
Why this matters
This update from the AMF relates to the marketing communications of collective investment schemes, which impacts asset managers and wealth managers. It touches on consumer protection and authorization/licensing requirements.
Asset management Update of the AMF's policy on funds that use Total Return Swaps and communicate about their consideration of non-financial criteria
Why this matters
This regulatory update from the AMF (French financial markets authority) is focused on funds that use Total Return Swaps and communicate about their consideration of non-financial criteria, which falls under the ESG/sustainability and reporting/disclosure topics.
Long term investment Shares Stimulating the diversification of long-term savings: the AMF proposes an educational approach to equity investment
Why this matters
This regulatory update from the AMF focuses on stimulating the diversification of long-term savings through an educational approach to equity investment. It is relevant for investment managers, wealth managers, and banks that offer long-term savings products.
Asset management Transposition of the directive on the cross-border distribution of collective investment undertakings: the AMF amends its General Regulation and its policy
Why this matters
This regulatory update from the AMF relates to the transposition of a directive on the cross-border distribution of collective investment undertakings. It impacts asset managers and wealth managers who distribute such funds across borders.