The AMF has introduced a new methodology for document-based inspections of financial investment advisor

Principles and objectives of the new CORE inspection methodology

In exercising its remit to supervise FIAs, the AMF uses a risk-based approach for which it maps all FIAs. This methodology makes targeted supervisory and inspection initiatives possible: analyses of annual data, website reviews, face-to-face meetings at the AMF and inspection proposals.

CORE inspections are document-based inspections carried out on a broad panel of supervised companies over several annual campaigns. They follow a risk-based approach, but also align with the AMF's supervisory priorities, both in terms of selection and following up on the inspections.

They can, subsequently, lead to on-site inspections (‘standard’ inspections). For missions that do not give rise to an on-site inspection, observation letters are sent to the FIAs, together with an analysis grid. This contributes to supporting market participants and ensuring they are compliant. It also makes it easier for the FIA professional associations to process the transmissions made by the AMF. The aim is also to bring the supervisory practices of FIA professional associations into line with those of the AMF. As a reminder, the AMF General Regulation stipulates that associations must carry out on-site inspections of each of their members at least once every five years.

A summary of the lessons leaned from the CORE inspections is intended to be published annually.

CORE inspection conduct and follow-up

The AMF Secretary General decides to open a CORE inspection. He issues an inspection order to the inspectors in charge of the inspection. These inspections are carried out using the AMF's internal resources exclusively.

Once appointed, the inspectors contact the inspected entity by telephone to explain how the inspection will be carried out. They email it their inspection orders, the inspection charter, the list of documents to be sent to them and a questionnaire to be returned once it has been completed.

The inspected FIA must send these documents to the inspection team over a secure messaging system no later than 10 working days after the documents are requested. Items that are not provided within the time limit are deemed not to exist.

Once these documents have been received by the inspectors, the analysis phase begins. This focusses on the inspected FIA’s compliance with its professional obligations. The inspection team may make additional requests to the inspected entity in order to supplement its analysis.

At the end of the inspection, there are several possible outcomes:

• either the inspection ends with an observation letter and an analysis grid being sent to the inspected FIA. These documents may also be transmitted to the professional association of which the FIA is a member, so that the latter can carry out supervisory work on the FIA's compliance with its professional obligations;
• or the inspection is continued in the form of a ‘standard’ inspection. New inspection orders are then drawn up to appoint a new inspection team, which can carry out on-site visits and draw up an inspection report.

Main observations arising from the CORE inspection campaigns carried out in 2025

Between June and December 2025, the AMF Inspection Department carried out 15 inspections using this new methodology in two campaigns.

These inspections identified several areas for improvement in FIA practices, particularly in terms of the quality of information on costs and fees, the collection and consideration of client sustainability preferences, and compliance with anti-money laundering and countering the financing of terrorism (AML/CFT) obligations.

• Information quality and justification of costs and fees

The two inspection campaigns highlighted the need for FIAs to maintain heightened vigilance with regard to communicating information on costs and fees to their clients. The findings suggest that FIAs do not systematically provide investors with complete, clear and easily understandable information that complies with the regulatory requirements.

A number of areas for improvement can be identified from the inspections carried out. In particular, gaps still appear to persist in the ability to present information that is truly tailored to the investor's situation, especially in terms of a personalised statement of costs based on the amount invested. Similarly, the distinction between the fees relating to the service provided and those relating to the financial instruments would benefit from further clarification. Finally, in some cases, there is still room for improvement in terms of the presentation of the cumulative impact of costs and fees on the performance of the investment. This is likely to limit a client’s full understanding of the situation.

In terms of the incentives received (remuneration, incentives or benefits from third parties), the situation appears to be more satisfactory overall, although refinements can still be made. Observations arising from the inspections highlight the need for some FIAs to be in a position to more clearly demonstrate that these incentives contribute to improving the service provided to clients.

• Sustainability preference collection and consideration

The inspection of the collection of client sustainability preferences, introduced on 1 January 2023 as part of FIAs’ professional obligations, revealed that FIAs’ appropriation of the regulatory requirements remains uneven.

73% of the FIAs inspected had included questions on sustainability preferences as part of the ‘know-your-customer’ process. However, in some cases, these systems remain incomplete. Our observations show that a third of the entities inspected do not ask their clients about the three regulatory areas: alignment with the European taxonomy, consideration of sustainable investments within the meaning of the SFDR Regulation and consideration of the principal adverse impacts (PAIs) of the investment made. Such an approach is likely to limit an FIA's ability to fully understand the sustainability preferences expressed by their clients.

In addition, areas for improvement can be identified in terms of formalising the preferences collected and translating them into operational advice. The use of sustainability preferences could be more structured to ensure that they are better taken into account.

Finally, at many of the FIAs inspected, there appears to be room for improvement in terms of the effective integration of sustainability preferences in the definition of target markets. These observations tend to highlight the persistent difficulties experienced by FIAs in ensuring consistency between the information gathered from clients and the characteristics of the financial instruments offered-in their advice, which is nevertheless crucial to the provision of tailored advice.

• Compliance with AML/CFT obligations

An analysis of the AML/CFT measures implemented by the FIAs inspected indicates that in some instances there is significant scope for improvement in FIAs’ practices.

The introduction of a risk classification system, designed to determine the level of vigilance applicable to clients, appears to be a crucial factor. In a significant number of cases, the existing systems need to be strengthened. Some entities do not have a classification system, or they have a document, but this does not include a relevant identification and prioritisation of risks.

The inspections also revealed the need to strengthen the client identity verification systems. A number of shortcomings have been identified, including a lack of sufficiently convincing supporting documentation and delays in carrying out the required checks.