meta_id 3013356

On 27 March 2026, the Autorité des marchés financiers (AMF) published clarifications to its doctrine applicable to asset management companies (AMCs) to address regulatory developments and professional needs. The AMF made several key adjustments. First, it made mandatory the description of digital operational resilience arrangements in AMCs' programmes of activity, in compliance with the Digital Operational Resilience Act (DORA) Regulation, which became applicable to UCITS AMCs and those fully subject to the Alternative Investment Fund Managers Directive (AIFMD) from 17 January 2025. AMCs have a six-month transitional period from the publication of the amended doctrine to update their programmes of activity on the ROSA extranet. Second, the AMF clarified that financial managers may perform non-regulated activities outside the AMC provided such activities do not jeopardise the continuity of the AMC's resources or create conflicts of interest. This does not affect existing expectations for shared financial portfolio managers performing other regulated activities. Third, the AMF simplified the process for closing authorisation withdrawal proceedings, allowing withdrawals to take effect at the end of a specified period without requiring the company to change its corporate purpose or legal name beforehand. The AMC remains obligated to amend its legal name and corporate purpose following the effective date of withdrawal. Additionally, the AMF clarified requirements for unit-linked arbitrage mandates under life insurance policies, the calculation of own funds, and conditions for AMCs to manage loan mandates as ancillary activities. Asset management companies should review the updated guidance and amend their programmes of activity accordingly within the six-month transitional period. References: AMF Instruction DOC-2008-03: Authorisation procedure for investment management companies AMF Position-Recommendation DOC-2012-19: Programme of operations guide for asset management companies