Key Takeaways:
- The AMF has published its 2026 Action and Supervision Priorities. For asset management companies, it announced the conduct of standard and “SPOT” inspection campaigns to assess risk management, remuneration policies, selection and monitoring of private equity investments, end-of-life of private equity funds and discretionary management.
- Reinforcing the attractiveness and competitiveness of the Paris financial center remains a key AMF objective, pursued through regulatory modernization and simplification and enhanced supervisory convergence at the European level.
INTRODUCTION
Each year, as part of its New Year’s address to the press, the Chair of the French Financial Markets Authority (the “AMF”) sets out the regulator’s new supervisory and enforcement priorities. The priorities for this year form part of the AMF’s “Impact 2027” strategy framework adopted in June 2023 and outline the direction of financial supervision in France for 2026.
The AMF has announced the conduct of five thematic Supervision des Pratiques Opérationnelles et Thématiques (“SPOT”) inspection campaigns, three of which are particularly relevant for the asset management industry: risk management; remuneration policies; and the selection and monitoring of private equity investments. The AMF also launched a marketplace consultation on the competitiveness of the framework for asset management companies (sociétés de gestion de portefeuille, “SGPs”), as part of the modernization of the French regulatory system.
SPOT THEMATIC SUPERVISORY PRIORITIES
The AMF will conduct SPOT inspection campaigns in the following areas:
Risk Management
As part of a common supervisory action conducted by the European Securities and Markets Authority (the “ESMA”), the AMF will carry out work relating to the risk management function of SGPs. It will conduct both (i) analytical work by way of a questionnaire sent to a broad range of market participants and (ii) SPOT inspections of a smaller sample of SGPs. In addition to organizational aspects and staffing (moyens humains), the procedural framework and reporting to governing bodies, the SPOT campaign will focus on the calculation of risk indicators (including Value-at-Risk calculations) and their appropriateness in light of the financial instruments and investment strategies used. Consistent with ESMA’s 2025 risk mapping, the inspections will pay particular attention to the fund’s use of leverage, assessing whether the SGP’s risk metrics and overall risk framework properly monitor and control the risks arising from leveraged strategies.
Remuneration Policies
The AMF will conduct SPOT inspections in 2026 relating to the remuneration policies established and implemented by a panel of SGPs, by reviewing the procedural framework, the governance and control arrangements and the criteria used to determine variable remuneration and its proportion within total remuneration, as well as the related deferral mechanisms.
SGPs should therefore be prepared to produce such documents and information to the AMF in case of an inspection and ensure that these comply with the applicable AMF rules and guidelines.
Selection and Monitoring of Private Equity Investments
Pursuant to the AMF’s 2025 Markets and Risks Outlook map, assets under management of French private equity funds increased by more than 5% in 2024 compared with the previous year, and retail investors’ appetite for this asset class continues to increase.
The AMF will devote a SPOT inspection campaign to this expanding line of business. The AMF will focus on the due diligence carried out by SGPs in connection with the selection and ongoing monitoring of private equity investments. Such due diligence must comply with the AMF General Regulation requiring SGPs to act with due skill, care and diligence in the best interests of the funds they manage and the AMF guidance on governance and conflicts of interest, as well as the AMF’s instructions and positions concerning knowledge of underlying assets.
The AMF will also review the applicable procedural framework, the deal flow generated by SGPs and the practical implementation of the investment and monitoring process for holdings, as well as the related controls. In this context, the AMF will examine (i) any use of external advisers or service providers to verify that it does not constitute a de facto delegation, in accordance with applicable delegation rules under the AMF General Regulation; (ii) the SGPs’ representation on the portfolio companies’ corporate bodies in the interest of the relevant funds; and (iii) the exercise by the SGPs of shareholder rights on behalf of and in the interest of the funds they manage.
NON-SPOT SUPERVISORY PRIORITIES
The AMF will conduct traditional inspection campaigns in the following areas:
End-of-Life of Private Equity Funds
Following the work of the working group set up by the AMF in 2022 on the end-of-life of private equity funds aimed at improving compliance with these funds’ liquidation deadlines and enhancing information provided to their unitholders, the AMF will review the steps taken by SGPs to anticipate and organize the liquidation of funds, in particular in cases of protracted wind-downs (i.e., where the statutory lifespan is exceeded, including any extensions). The AMF will also review the information provided to unitholders and the handling of complaints relating to such overruns.
As in 2025, the AMF will pay particular attention to transfers of portfolio companies and interests between portfolios to ensure that the interests of the acquiring funds are preserved. While such transfers may be permitted, they remain governed by the codes of conduct of the professional associations approved by the AMF and are subject to rigorous controls, particularly as regards the valuation used.
Discretionary Management
In 2026, the AMF will carry out standard inspections of SGPs’ discretionary portfolio management activity to check that ex-ante and ex-post information are provided to clients, particularly in relation to costs and fees.
In the context of the management of individual portfolios, SGPs may invest in certain funds (UCITS and AIFs) they manage (the so-called “in-house funds”). While such practice may be consistent with an overall asset-bucket allocation policy and may generate economies of scale, it also gives rise to potential conflicts of interest that must be appropriately managed. The AMF’s inspection will therefore aim to ensure that investments in in-house funds are consistent with clients’ objectives and with the associated remuneration arrangement.
OTHER PRIORITIES FOR FRENCH ASSET MANAGEMENT
The AMF is particularly committed to enhancing the competitiveness of the Paris financial center by simplifying applicable rules and supporting market participants in their implementation.
Following the revision of the Regulation on European Long-Term Investment Funds (ELTIF II), the AMF will continue its work (together with the French Treasury) to enhance the coherence, readability and attractiveness of the French domestic fund range. In this context, it will modernize the rules applicable to alternative fund-of-funds structures to allow them to hold unlisted assets, such as private debt. Such modernization would align the French alternative fund-of-fund regime with the expanded possibilities under ELTIF II, which permits ELTIFs structured as fund-of-funds to access unlisted assets directly or through investments in EU AIFs managed by EU AIFMs.
The AMF will further simplify the management companies’ operating rules, including by reviewing its supervisory doctrine on issues identified in the consultation (e.g., remuneration rules, barriers to investment in unlisted assets).
From April 2026, the AMF will also support market participants with the implementation of the measures introduced by the revised Alternative Investment Fund Managers Directive (AIFMD II). For that purpose, the French authority will focus on the implementation of liquidity management tools, which certain French UCITS and AIFs will be required to put in place (including redemption gates, extended notice periods, redemption fees, swing pricing and similar mechanisms).
As regards asset management, the European Commission published on 20 November 2025 a proposal for a revision of the Sustainable Finance Disclosure Regulation (SFDR II) establishing a framework for sustainability-related disclosures applicable to financial entities and products (please see our Debevoise InDepth here). The AMF will support the French public authorities in these negotiations, advocating for clear classification criteria and for the framework to apply to all similar financial products between which investors could choose. Clear criteria and consistent application would prevent regulatory arbitrage where other market participants could avoid stricter rules by packaging similar products differently, which would disadvantage SGPs that comply with more stringent regulations.
This publication is for general information purposes only. It is not intended to provide, nor is it to be used as, a substitute for legal advice. In some jurisdictions it may be considered attorney advertising.