In June 2026, the AMF-ACPR Joint Unit published an in-depth study on the distribution, costs and performance of structured products marketed in France. Based on information collected from issuers, insurers, banks, investment advisers, wealth management firms and distribution platforms, the report highlights a rapidly growing market while identifying several areas of regulatory and economic concern.
The study finds that the initiative to create structured products increasingly originates from the final distributor, particularly in the case of bespoke products designed for a limited number of investors. This development reinforces distributors’ responsibilities regarding product design and compliance with the fundamental principle of acting in the best interests of clients.
The authorities identified numerous compliance shortcomings throughout the distribution chain. The main weaknesses relate to target market definition, identification of negative target markets, assessment of investors’ knowledge and experience, and pre-contractual disclosure of costs and charges. In several cases, distributors simply relied on target markets defined by manufacturers without conducting their own assessment, contrary to regulatory requirements.
The report also highlights significant delays in the implementation of ACPR recommendations concerning the definition of specific target markets for complex unit-linked products distributed through life insurance contracts. Two-thirds of the products reviewed were not yet fully compliant with requirements applicable since 1 January 2024.
From a commercial perspective, issuers, insurers and intermediaries have generally implemented support and training arrangements for final distributors. The study identifies several good practices, including technical knowledge testing, product monitoring platforms and enhanced investor consent procedures for more complex products.
The analysis of costs reveals a remuneration structure that remains particularly difficult for investors to understand. Costs are embedded within the product rather than charged through explicit commissions. Within the sample analysed, the average total entry cost amounted to 5.83% of the investment, with some products exceeding 13%. The allocation of these costs among issuers, distributors, intermediaries and insurers remains largely opaque to end investors.
Regarding performance, the report reminds investors that structured products offer an asymmetric risk-return profile. In exchange for full or conditional capital protection, investors generally forgo part of the upside potential of the underlying markets. Over the 2022–2024 period, which was characterised by generally favourable equity market conditions, the products analysed underperformed comparable index-based investments on the same underlying assets by approximately 2.4 percentage points.
The authorities also stress that capital protection mechanisms are often conditional, apply only at maturity and remain subject to issuer credit risk. In the event of early redemption or significant market declines, investors may suffer partial or even total capital losses.
In conclusion, the AMF and ACPR acknowledge that structured products may serve certain investment objectives. However, they emphasise the need for stronger product governance, greater transparency regarding costs and charges, more robust target market definitions and clearer investor disclosures to ensure that investors fully understand the trade-off between potential returns and capital protection.
Key Takeaways for Financial Institutions
- Expected strengthening of product governance frameworks and target market definitions;
- Increased scrutiny of investor knowledge and experience assessments;
- Need to improve transparency and disclosure of costs and charges;
- Importance of documenting the economic rationale of structured products compared with alternative investment solutions;
- Particular attention required for bespoke products and complex or decrement-based indices;
- Increased supervisory focus on the distribution practices of intermediaries and final distributors.
This study is likely the most comprehensive reference document published to date by the French authorities on the practical functioning of the structured products value chain, covering product design, distribution and remuneration mechanisms.
CerLab Finance supports asset managers and institutional investors in preparing for these regulatory developments, through tailored regulatory due diligence, internal framework reviews, and strategic sectoral monitoring.