The 2024 Annual Report of the Autorité des marchés financiers (AMF), published on 26 May 2025, provides a comprehensive overview of the regulator’s actions in a context of profound transformation in both regulatory and operational expectations within the financial sector.
CerLab Finance offers a targeted summary for asset management companies, investment service providers (ISPs), and crypto-asset service providers (CASPs)—the new designation under the MiCA regulation:
A Cautious Implementation of the SFDR Regulation
In its SPOT inspections, the AMF highlights the uneven application of sustainability criteria (SFDR regulation) across asset management practices. While there has been progress in ESG documentation, discrepancies remain between the declared sustainability objectives and the actual data disclosed.
Mystery Shopping and Client Sustainability Preferences: Still Lacking
Mystery shopping exercises revealed that ESG preferences are still insufficiently considered during subscription meetings. The regulatory obligation to collect client sustainability preferences is often fulfilled in a formalistic manner, with little real customisation of the advisory process.
DORA Regulation: In Force and Heightened Vigilance
With the entry into force of the Digital Operational Resilience Act (DORA), ISPs and asset managers are now required to establish clear governance over IT risk. The AMF calls for strengthened anticipation in mapping critical service providers, particularly in outsourced functions (e.g., IT, custodians).
Preparing for MiCA: A Transition Year
Since July 2024, the AMF has begun receiving the first applications for CASP authorisation. The regulator emphasises the need for legacy PSANs (digital asset service providers) to upgrade their capabilities in governance, client protection, and financial robustness. Awareness and education campaigns have been launched in this regard.
Thematic SPOT Inspections of ISPs and Asset Managers
The AMF has conducted targeted SPOT inspections focusing on:
- The quality of regulatory reporting (AIFM, MMF, ROSA), which is frequently outsourced and exposed to reliability risks;
- Customer complaint handling frameworks, which remain suboptimal in several firms;
- Delegation of portfolio management: the AMF reminds firms that final responsibility always lies with the delegating entity—even within the same group.
Marketing and Product Monitoring: Increased Scrutiny
The marketing of real estate collective investment vehicles (SCPI) under temporary dismemberment arrangements was subject to SPOT review. The AMF observed insufficient information on costs, objectives, and specific risks associated with this complex investment structure. Post-sale monitoring remains weak, particularly among distributors.
Sanctions: ISPs and Management Firms in the Regulator’s Crosshairs
In 2024, the AMF issued 12 enforcement decisions, totalling €26.5 million in fines—several of which targeted ISPs and asset managers. Violations included:
- Deficiencies in internal control systems;
- Non-compliant marketing practices;
- Mismatch between client profiles and products recommended.
Conclusion
The 2024 report confirms the AMF’s increasingly operational and targeted enforcement approach. For management companies, distributors, regulated service providers, and crypto-asset service providers, it is essential to:
- Review governance, sustainability, marketing, and reporting frameworks;
- Anticipate the combined impact of MiCA, DORA, and SFDR;
- Strengthen relationships with custodians and delegated service providers.
CerLab Finance supports its clients throughout this compliance transition through tailored regulatory due diligence, internal control reviews, and sector-specific strategic monitoring.