TITLE: France's Financial Markets Authority Confirms Money Market Fund Classification as Cash Equivalents
BODY:
On July 30, 2026, the Autorité des Marchés Financiers (AMF) confirmed guidance from the Autorité des Normes Comptables (French Accounting Standards Authority, ANC) regarding the classification of money market funds (MMFs) as "cash equivalents" under European accounting standards.
The clarification addresses requirements introduced by Directive (EU) 2024/927 (Alternative Investment Fund Managers Directive II, AIFMD II), which mandates that asset management companies select at least two liquidity management tools for UCITS and open-ended alternative investment funds (AIFs). However, funds authorised under Regulation (EU) 2017/1131 on MMFs are required to select only one liquidity management tool. In a letter dated July 8, 2026, the ANC confirmed that the presence of liquidity management tools—such as swing pricing—does not undermine the presumption that variable net asset value (VNAV) MMFs, whether standard or short-term, qualify for classification as "cash equivalents". This position responds to a question raised by the Association Française de la Gestion Financière (AFG), with analytical support from the AMF. The ANC noted that this presumption remains rebuttable, particularly during periods of market stress or when such liquidity management tools are activated.
The AMF will incorporate this ANC position into its updated guide on money market funds. Asset managers relying on this guidance should monitor for any future updates to the AMF's guidance and remain alert to circumstances that could trigger the rebuttal of the presumption, particularly during volatile market conditions.
**References:**
- ANC letter of July 8, 2026 (in French only)
- Directive (EU) 2024/927 of March 13, 2024 (AIFMD II)
- Regulation (EU) 2017/1131 on money market funds