The ACPR and AMF Joint Unit publishes its analysis on the distribution, fees and performance of structured products

Against a backdrop of strong growth in the structured products market, the ACPR-AMF Joint Unit continues to pay particular attention to these products, which are sold to retail investors through life insurance policies and securities accounts. In 2025, the two authorities had examined annual inflow trends, the main marketing channels and the characteristics of these products ⁽¹⁾. The two authorities are now continuing this work with the publication of a new analysis focusing on their fees, performance and distribution arrangements.

This study was carried out with stakeholders representing the entire distribution chain (issuers, insurers and distributors) and selected based on their representativeness. It covers a sample of products marketed between 2023 and the first half of 2025. Given the current bull market conditions, the study’s outcomes do not necessarily reflect those that would be obtained in a bear market.

By identifying the distribution arrangements for these products, this study aims to ensure that professionals comply with their obligations, particularly in terms of product governance and supervision, and to identify the measures implemented by distributors to ensure that clients receive suitable advice.

With regard to the fees and performance of structured products, the study found, in particular, that:

• of the 51 products analysed, the total entry cost varies significantly from one distributor to another, ranging from 1.20% to 13.16%, depending on the distribution arrangements and the type of distributor. Over the period under review, the average cost stood at 5.83%;
• as these fees are incorporated into the product’s financial structure rather than being invoiced separately, they can be difficult for investors to understand. They are generally paid in full at the time of purchase and do not vary depending on the product’s actual duration;
• on average, the performance of the products analysed was lower than the markets’ performance over the 2022-2024 period. This difference can be explained by the impact of the cost of these products and by the possibility of full or conditional capital protection at maturity.

This study has identified several best practices, including:

• the verification of end distributors’ competences by intermediate distributors;
• a framework for selecting complex products in life insurance policies using a set of specifications;
• the provision of specific annexes when subscribing structured products, designed to draw clients’ attention to the main risks and characteristics of these products.

Nevertheless, the Joint Unit has identified instances of non-compliance. The authorities therefore wish to draw professionals’ attention to their obligations:

• target markets must be sufficiently specific and tailored to the characteristics of the products and the profiles of the clients for whom they are intended (particularly in terms of investment horizon, ability to bear losses, risk tolerance, etc.);
• since 1 January 2024, insurers have been required to define a specific and negative target market for complex unit-linked products. These target markets must be communicated to distributors and are in addition to the target market of the life insurance policy itself. Insurers, as the designers of life insurance policies and the ones who select complex unit-linked products, must monitor these products after they have been brought to market;
• clients’ experience and knowledge must be verified in order to reduce the risk of mis-selling;
• the information provided to clients, particularly regarding fees, must comply with the applicable requirements and be clear, accurate and not misleading. The shortcomings identified relate in particular to the annualised presentation of fees, the lack of a clear breakdown between product costs and service costs, and the absence of any specific mention of any retrocessions received from the manufacturer.

All instances of non-compliance identified are subject to bilateral supervisory work involving the market participants concerned. The authorities will continue to exercise particular vigilance over the distribution of structured products, through supervisory work and inspections.

Given the complexity of these products and the risks they may pose to retail investors, the ACPR-AMF Joint Unit wishes to draw their attention to several points requiring particular caution:

• structured products are complex instruments whose returns and potential capital protection depend on conditions that may be difficult to understand;
• depending on market conditions and the issuer’s situation, the investor may suffer a partial or total loss of the capital invested;
• a retail investor should not invest in a structured product if he or she is unable to understand how it works, its performance terms and the risk of loss. In this context, the distributor plays a crucial role in ensuring not only that the product aligns with the client’s risk tolerance and objectives, but also that the client understands the risks to which he or she is exposed.

About the AMF
As an independent public authority, the Autorité des Marchés Financiers (AMF) protects savings invested in financial products, ensures that investors receive clear and reliable financial information, and maintains orderly financial markets. Through its engagement with European and international regulatory bodies, the AMF contributes to financial stability and effective regulation. The AMF develops and enforces regulatory standards, supervises market participants and market infrastructures, and takes action against misconduct and regulatory breaches. It also supports the transformation of the financial sector, particularly in the areas of innovation and sustainable finance. As an impact-driven regulator, the AMF acts in the public interest.

Regulate finance, reinforce confidence.

Visit our website:  https://www.amf-france.org/en

About the ACPR
The Autorité de Contrôle Prudentiel et de Résolution is the administrative authority operationally attached to the Banque de France that supervises the banking and insurance sectors and ensures financial stability. The ACPR is also responsible for protecting the customers of the supervised institutions and ensuring the fight against money laundering and the financing of terrorism. It also has resolution powers. The ACPR’s operational departments come under its General Secretariat. 

Visit our website: https://acpr.banque-france.fr/