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. A potentially reduced cushion is available for OPCIs and evergreen FCPRs marketed exclusively through eligible insurance or savings products, subject to the conditions in Instruction DOC-2026-05. The minimum cushion must be described in the OPCI prospectus or evergreen FCPR rules using the relevant standard documentation format in Annex VII of Instructions DOC-2011-22 and DOC-2011-2
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 an
Who is affected
Related regulations
References
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What the AMF said
Collective investments Asset management The Autorité des Marchés Financiers (AMF) has published a new instruction covering liquidity management procedures at OPCIs and evergreen FCPRs
Published by AMF . Read the full notice at the source for the authoritative text.