France's Financial Markets Authority has updated its doctrine on the registration of legal entities, other than portfolio management companies, that manage certain other alternative investment funds. The update clarifies the limited circumstances in which managers may operate under a registration regime rather than seek authorization as a portfolio management company, and reiterates that this status does not confer an EU passport to manage or market AIFs in other member states. The regime remains available only where a manager exclusively manages one or more other AIFs, keeps assets under management below the applicable EUR 100 million or EUR 500 million thresholds, and limits investors in those AIFs to professional investors. The revised instruction specifies that professional investor status must be met both at subscription and throughout the period the investor remains a unitholder or shareholder. It also aligns the concept with the French professional client definition, including eligible elective professional clients, while noting that only an investment services provider may classify a client as an elective professional and only when providing an investment service. Managers are also reminded to ensure that any communications about themselves or the AIFs they manage do not create confusion about the scope of their registration. The update further states that assets held by each managed other AIF must be valued properly at fair value, that registration must be requested no later than one month before management activity begins, and that any changes affecting the manager or the AIFs under management must be notified to the authority. A manager that has ceased managing other AIFs and does not intend to start new activity within the next six months must apply for deregistration. If the registration conditions are no longer met, the manager must seek authorization as a portfolio management company.
France Autorite des marches financiers2026-06-15
France's Financial Markets Authority updates guidance for managers of certain other AIFs and clarifies registration conditions
France's Financial Markets Authority has updated its guidance for registered managers of certain other AIFs, clarifying when they may rely on registration instead of full authorization. The changes tighten expectations around professional investor status, communications, valuation and notification duties. Managers must apply at least one month before starting activity and seek deregistration if they stop managing such AIFs and do not plan to resume within six months.