Mystery shopping visits to bank branches: the AMF calls on professionals to improve the quality of client questioning and the presentation of fees

Since 2010, the AMF has been conducting mystery shopping visit campaigns, at both bank branches and online, in order to monitor financial instrument marketing practices and ensure compliance with the Markets in Financial Instruments Directive (MiFID II), which aims to enhance investor protection. Conducted by a specialised research institute and based on a scenario defined by the AMF, these visits constitute a tool for monitoring and entering into dialogue with the institutions visited, with the aim of improving marketing practices.

For this new campaign, entitled risk-averse/risk-loving, 145 mystery shopping visits were carried out at 11 major high street banks.  In most cases, the mystery shopper played the role of a prospect, who did not open an account and allowed the advisor to offer them financial products spontaneously. In other cases, the mystery shopper made a subscription, by opening an ordinary securities account and investing in it. In both cases, the mystery shopper assumed either the profile of a retail investor who favoured prudent management of their assets or that of a retail investor willing to take risks to increase the value of their capital.

At the end of this campaign, the AMF made the following main observations:

• for certain items the quality of the questions asked appears insufficient and lower than during the two previous campaigns, initiated in 2022 and 2019, such as those necessary to assess retail investors’ financial situation and their ability to bear capital losses;
•  plans and the investment horizon are well covered – more than four out of five visitors were asked about these items – but risk tolerance and sustainability preferences were broached at only one in two visits. Financial knowledge was assessed during more than two out of three appointments and financial experience at one in two;
• in terms of commercial proposals, life insurance was still the most frequent proposed wrapper by bank advisors, irrespective of the mystery shopper’s profile. However, equity savings plans (PEA), retirement savings plans (PER) and securities accounts gained ground. Thus, a PEA was proposed in more than 60% of cases;
• in terms of products, advisors put equity funds, bond funds, ETFs and structured funds and products forward more than in the past. Thus, 53% of risk-averse prospects were offered equity funds (compared to 18% in 2022) and 27% bond funds; the finding was similar for the risk-loving profile, with 65% proposed equity funds and 32% bond funds. For the mystery shoppers who wanted to make a subscription, 52% were offered equity funds, 48% ETFs, 35% bond funds and 35% structured funds or structured products. Conversely, proposals of SCPIs have declined sharply compared to 2022;
• PEA and securities account fees were presented at only 29% of risk-averse visits and 36% of risk-loving visits. In term of the financial instruments recommended, fees were set out at less than one in three appointments.
• the provision of regulatory documents, such as the key information document (KID), was significantly down compared to 2022: 9% of risk-averse visitors reported having received such documents (compared to 23%) and 13% of risk-averse visitors (compared to 24%);

These findings varied depending on the context of the appointment. In a subscription situation, where onboarding was formalised and the obligations arising from MiFID II were fully applicable, the practices observed were more favourable than during a prospective visit: more in-depth questions were asked in relation to several essential items, the presentation of the products, costs and fees was more frequent, and the provision of documentation was more systematic. Nevertheless, these improvements still fell short of the levels expected under the regulations.

Over the past few weeks, the AMF has met with each of the institutions visited to review the results of this campaign, suggest areas for improvement and discuss any difficulties encountered.

In 2025, as part of their Joint Unit, the AMF and the ACPR initiated a five-year retrospective analysis of professionals’ practices, based on the lessons learned from their respective inspections.  This analysis, the conclusions of which will be published before the end of the year, will help to identify any recurring difficulties in applying the regulations. In a document published in November 2025, the two authorities put forward practical solutions to help professionals take sustainability preferences into account, through appropriate assessment tools, best practices for asking clients questions and a clarification of the obligations.

Finally, these findings come in an evolving regulatory context. The European Union’s future strategy for retail investment aims to strengthen supervision of promotional marketing materials and overhaul the fee transparency mechanism. With this in mind, the AMF calls on professionals to strengthen the quality of the questions they ask, information about fees and the provision of regulatory documents, so that their commercial practices are fully compliant with the regulations.