The Autorité des Marchés Financiers (AMF) released its final guidelines for managed account management on June 3, 2026, aiming to standardize oversight of investment mandates in France.
AMF Publishes Final Guidelines for Managed Account Management
The French financial regulator, the Autorité des Marchés Financiers (AMF), finalized its framework for managing investment mandates on June 3, 2026, marking a significant step in aligning oversight with evolving market practices. The document, titled “Guide for the Management of Investment Mandates,” outlines procedural requirements, transparency obligations, and risk management protocols for firms handling client assets under delegated authority.
The guidelines address gaps identified in the 2024 review of managed account operations, where the AMF noted inconsistencies in how firms disclosed fees, managed conflicts of interest, and reported performance. “The new framework ensures clarity for investors and consistency among market participants,” stated the AMF in its official release. The document emphasizes the need for real-time reporting of mandate changes and enhanced due diligence for third-party service providers.
Key Provisions and Industry Reactions
The AMF’s guide mandates that firms establish internal governance structures to monitor mandate execution, including quarterly audits and annual third-party reviews. It also requires detailed fee breakdowns for clients, prohibiting hidden charges tied to performance benchmarks. “These measures address long-standing concerns about opacity in managed accounts,” said a spokesperson for the French Association of Asset Managers (AFA), a trade group representing over 300 firms.
One notable provision is the requirement for firms to disclose the “cost of capital” associated with mandate management, a metric critics argue could complicate fee structures for smaller investors. The AMF defended the rule, stating,
“Transparency in cost allocation is essential to prevent misalignment between client interests and manager incentives.”
AMF Chairperson Laurence Berthelot
.
Industry stakeholders have mixed views. While larger asset managers welcomed the standardization, smaller firms raised concerns about compliance costs. “The documentation burden could disproportionately affect boutique firms,” said a representative from the French Independent Asset Managers Association (AIGA). The AMF acknowledged these challenges, noting that transitional periods would be available for firms with fewer than 500 clients.
Regulatory Context and Global Trends
The AMF’s move aligns with broader European Union efforts to harmonize oversight of investment mandates. In March 2026, the European Securities and Markets Authority (ESMA) issued similar recommendations, urging member states to adopt “enhanced transparency frameworks.” The AMF’s guidelines, however, go further by introducing mandatory performance benchmarks tied to client risk profiles.
Global regulators have also been scrutinizing managed accounts. In the U.S., the Securities and Exchange Commission (SEC) proposed rules in 2025 requiring detailed disclosures for separately managed accounts (SMAs), a parallel to the AMF’s approach. “The trend reflects growing investor demand for accountability in delegated investment decisions,” said Dr. Elena Moreau, a financial regulation expert at the University of Paris.
The AMF’s framework also incorporates feedback from a 2025 consultation period, during which 142 firms and 27 investor groups submitted comments. Key changes include relaxing reporting deadlines for mandates under €10 million and allowing limited exemptions for non-profit entities managing public assets.
Next Steps and Ongoing Debates
The AMF’s guidelines take effect on January 1, 2027, with a six-month grace period for compliance. Firms must submit implementation plans by September 30, 2026, and the regulator will conduct audits starting in Q2 2027. A spokesperson for the AMF confirmed,
“We will work closely with firms to ensure a smooth transition, but non-compliance will result in penalties under Article 14 of the Financial Markets Code.”
AMF Compliance Division
.
Debates persist over the guide’s scope. Critics argue that the emphasis on documentation may stifle innovation in personalized investment strategies, while supporters highlight its role in preventing conflicts of interest. The French Senate is expected to review the guidelines in July 2026, though the AMF has stated that the framework is “final and non-negotiable.”
As the deadline approaches, firms are scrambling to adjust their operational models. A survey by Deloitte France, conducted in May 2026, found that 68% of asset managers had initiated internal reviews, though only 22% felt fully prepared for the new requirements. The AMF has launched a dedicated portal to provide resources, including templates for compliance plans and FAQs on mandate structuring.
