In an increasingly digital investment landscape, the AMF stresses the importance of the quality of the information provided to retail investors throughout the investor journey

In a savings landscape that is undergoing radical change with the rise of digital solutions, the information provided to retail investors throughout their investment journey is key to their protection. This information must be provided to the same high standards and be of the same high quality whether the client is using a website or application alone, or is sitting with an advisor in a branch. To ensure that this is the case, the Autorité des Marchés Financiers made digitised journeys offered to retail clients one of its supervisory priorities for 2025.

As part of its SPOT (Operational and Thematic Supervision of Practices) inspections, the AMF examined the practices of four separate institutions authorised to provide investment services. The first three have a network of branches. The fourth presents a 100% online offer. For each of them, for the period from 1 January 2023 to 31 May 2025, the AMF looked at the entire digital journey, from the presentation of general information accessible on websites and client areas to the placing of orders.

Thus, it reviewed the procedures for gathering the information required on entering into a relationship, when opening an ordinary securities account or an equity savings plan. It explored the administration of the client questionnaire provided for in the European regulation on markets in financial instruments, which is used to get to know investors better, and to assess their knowledge and experience of financial matters. Finally, it analysed the impact of these systems on investor profiling and, consequently, on client protection.

The AMF has published the findings of its inspections in a summary document. At present, the services offered vary considerably from one institution to another: for two of the institutions inspected, it is not possible to open a securities account or PEA directly online, as the digital service remains focused on order placement, while the initial contact and collection of client information is carried out in branch. At another institution, the AMF noted a gradual increase in the number of financial instrument accounts opened online, although this does not yet account for the majority of such accounts opened. Only one institution offers the entire journey online.

The AMF identified several areas of weakness during its inspections. It encourages professionals wishing to develop their online or app-based investment services to be particularly vigilant in four areas:

• providing comprehensive, easy-to-read information to clients: of the providers inspected, the AMF found that some essential information, such as the nature of the services offered online, was presented in an incomplete manner or was difficult to understand. Furthermore, the use of client questionnaires covering all investment services when only the service of reception and transmission of orders is offered online may create confusion as to the nature of the service provided;
• strengthening the robustness of client questionnaires: the systems used to assess investor profiles vary considerably. Certain information-gathering practices, such as a small number of questions about the complex products offered or the insufficient granularity of the questions, appear likely to limit the reliability of the process for assessing the suitability of the envisaged financial products for the investor's profile. In addition, the AMF has noted that, in some cases, in the absence of sufficient supervision, clients are free to change questionnaire answers frequently, which weakens their protection;
• improving the effectiveness of warnings: warning messages about inappropriate products are sometimes ambiguous. In some cases, the way they are worded may minimise the impact of the warning, at the risk of undermining the client's understanding;
• adapting control systems: at the institutions on the panel, internal controls are still insufficiently attuned to the specific features of digital client journeys, even though the autonomy enjoyed by online clients is a major area of risk.

Protecting investors is one of the regulator's core missions, and one of its strategic priorities. The digitisation of financial services and the resulting physical distance between advisor and client must not be synonymous with a deterioration in the information provided to investors or in the processes for gathering the information needed to determine their profile.

About the AMF
The AMF is an independent public authority responsible for ensuring that savings invested in financial products are protected and that investors are provided with adequate information. The AMF also supervises the orderly operations of markets. Visit our website: https://www.amf-france.org/en