AMF Clarifies Asset Management Doctrine, DORA, and Financial Manager Roles
Summary
The AMF France has updated its doctrine for asset management companies, incorporating DORA requirements and clarifying rules for financial managers. Asset management companies must update their programs of activity by October 2026 to reflect digital operational resilience arrangements.
What changed
The Autorité des marchés financiers (AMF) France has issued updated guidance clarifying its doctrine for asset management companies, particularly concerning the Digital Operational Resilience Act (DORA) and the roles of financial managers. Effective January 17, 2025, asset management companies must integrate DORA compliance into their programs of activity, detailing digital operational resilience arrangements. The AMF is providing specific instructions for section 2.C of these programs.
Asset management companies are granted a six-month transitional period from the publication date of the amended doctrine to update their programs of activity on the ROSA extranet, meaning compliance with the DORA-related program updates is expected by approximately October 2026. Additionally, the AMF has clarified that financial managers may undertake external activities provided these do not compromise company resources or create conflicts of interest, without impacting existing expectations for shared portfolio managers performing other regulated activities.
What to do next
- Update program of activity to include DORA digital operational resilience arrangements by October 27, 2026.
- Review and ensure financial manager external activities comply with conflict of interest and resource continuity requirements.
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The AMF clarifies its doctrine on several aspects relating to asset management companies
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The AMF clarifies its doctrine on several aspects relating to asset management companiesPartager sur Facebook
27 March 2026
The AMF clarifies its doctrine on several aspects relating to asset management companies
The AMF has made several adjustments to its doctrine applicable to asset management companies in order to take account of certain regulatory developments and to address clarification needs expressed in particular by professionals.
Consideration of the DORA Regulation in asset management companies’ programme of activity
From 17 January 2025, UCITS asset management companies and those fully subject to the AIFM Directive must comply with the requirements set out in the DORA Regulation.
In this context, the AMF is making it compulsory for asset management companies to describe their digital operational resilience arrangements in their programmes of activity and is providing instructions as to the components of the digital resilience arrangements that must be presented in the standard form of section 2.C of the programme of activity.
Asset management companies are granted a six-months transitional period, from the date of the publication of the amended doctrine, to update their programme of activity on the ROSA extranet.
Clarification of the doctrine on time-sharing for financial managers
The AMF is clarifying the framework within which a financial manager may perform another function or activity outside the asset management company. Thus, a financial manager may perform another, non-regulated activity outside the asset management company if:
- the performance of this other function does not jeopardise the continuity of the AMC’s resources; and
- the performance of this other function does not place this person in a situation of conflict of interest. This clarification does not affect the AMF's existing expectations applicable to shared financial portfolio managers who perform other regulated activities outside the AMC.
Changes to the process for closing AMC authorisation withdrawal proceedings
In order to facilitate the closure of proceedings to withdraw the authorisation of asset management companies, the withdrawal of authorisation may take effect at the end of a specified period, without waiting for the company to have changed its corporate purpose or legal name.
As of the effective date of the withdrawal of authorisation, the asset management company remains required, in accordance with Article L. 532-10 of the Monetary and Financial Code, to amend its legal name and corporate purpose.
Arbitrage mandates for life insurance and the provision of portfolio management services
The AMF had already recalled the requirements applicable to unit-linked arbitrage mandates under life insurance policies, in connection with the recent reform of French law in the Green Industry Act, which regulates this activity for mandates entered into on or tacitly renewed from 24 October 2024.
The AMF thus clarified that asset management companies managing arbitrage mandates still subject to the old regime must continue to comply with the organisational and conduct rules applicable to the service of portfolio management on behalf of third parties.
It also indicated that the rules to be applied are those in force at the time the activity is carried out, and not those applicable at the time the doctrine was updated in relation to the Green Industry Act.
The AMF further points out that the arbitrage mandate business is distinct from the service of portfolio management on behalf of third parties, and that if an asset management company provides this investment service, including to an insurer by managing part of its assets, then it must comply with the rules applicable to this service.
Change to the table used to calculate own funds
Annex II of the guide to preparing the programme of activity of asset management companies includes a simplified table to help asset management companies to calculate regulatory own funds.
The AMF is clarifying the wording of this table in order to avoid any confusion surrounding the possibility of deducting corporation tax.
Mandates to grant or manage loans outside managed funds
The AMF is also clarifying the conditions under which an asset management company may be entrusted, as an ancillary activity, with a mandate to grant loans in the name and on behalf of a lender and/or to manage the loans granted by the latter.
Read more
- AMF Instruction DOC-2008-03: Authorisation procedure for investment management companies, disclosure obligations and passporting (in French only)
- AMF Instruction AMF DOC-2008-03: Apparent changes (in French only)
- Annex I AMF Instruction DOC-2008-03: Apparent changes (in French only)
- Annex 2C AMF Instruction DOC-2008-03: Apparent changes (in French only)
- AMF Position-Recommendation DOC-2012-19: Programme of operations guide for asset management companies and self-managed collective investments (in French only)
- AMF Position-Recommendation DOC-2012-19: Apparent changes (in French only) Keywords
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