ACPR and AMF Joint Approach on Client Sustainability Preferences

France ACPR News

Published December 2nd, 2025

Detected March 13th, 2026

Summary

The ACPR and AMF have jointly developed a supervisory approach to help financial investment advisers and life insurance professionals comply with client sustainability preferences under MiFID II and IDD. This guidance aims to facilitate the effective application of regulatory requirements and enhance client protection.

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What changed

The ACPR and AMF have released a joint supervisory approach designed to assist financial investment advisers and life insurance professionals in meeting the regulatory requirements for assessing and incorporating clients' sustainability preferences. This initiative addresses the complexity and lack of clear criteria for sustainable investments, noting that many current advisory processes do not fully comply with the framework and clients often do not articulate detailed sustainability preferences.

This guidance provides a pragmatic framework for professionals to effectively implement the sustainability preference assessment mandated by MiFID II and IDD. Compliance officers should review this approach to ensure their firm's processes align with the joint supervisory expectations, particularly concerning the assessment of client knowledge, financial situation, risk tolerance, and sustainability objectives. While no specific deadline is mentioned, adherence is crucial for maintaining client protection and regulatory compliance.

What to do next

Review the joint supervisory approach from ACPR and AMF regarding client sustainability preferences.
Assess current client profiling processes to ensure alignment with new guidance on sustainability preferences.
Update advisory documentation and training materials as necessary to reflect the joint approach.

Source document (simplified)

To support professionals, the ACPR and the AMF have jointly developed a pragmatic supervisory approach, aimed at facilitating the effective application of the regulatory requirements while maintaining a high level of client protection.

The regulatory framework requires financial investment advisers and life insurance professionals to assess their clients' investment profile: experience and knowledge, financial situation, risk tolerance and other investment objectives. Since August 2022, the European regulatory framework resulting from the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive (IDD) has required these professionals to also take account clients' sustainability preferences when offering them suitable investments.

In the absence of classification of financial products based on clear and objective sustainability criteria, the regulatory concepts defining the sustainability of investments often remain little-known and complex to grasp, for both advisers and clients. The ACPR and AMF’s results of the work show that most advisory process do not comply with the regulatory framework’s requirements, and that most clients do not formulate detailed sustainability preferences regarding MiFID II and IDD's three regulatory sustainability criteria.

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