France's Financial Markets Authority (AMF) has updated its supervisory doctrine for portfolio management companies, aligning it with regulatory developments and issuing clarifications requested by market participants. The package adds new expectations for documenting compliance with the EU Digital Operational Resilience Act (DORA) and revises guidance on staffing, authorisation withdrawals, life-insurance arbitration mandates, own funds calculations and ancillary loan mandates. For UCITS portfolio management companies and firms fully subject to the Alternative Investment Fund Managers Directive, the activity programme must now include a description of the digital operational resilience framework, with instructions on what to provide in the standard template for section 2.C. The doctrine also clarifies that a portfolio manager may undertake a separate, non-regulated activity outside the management company where this does not undermine the permanence of the firm’s resources and does not create conflicts of interest, without changing existing expectations for shared managers who also carry out other regulated activities. To facilitate closure of authorisation withdrawal procedures, a withdrawal can take effect after a defined period without waiting for the company to change its corporate purpose and name, while the company remains obliged to amend both by the effective date under Article L. 532-10 of the Monetary and Financial Code. On unit-linked arbitration mandates under life insurance contracts, the AMF reiterates the post–24 October 2024 framework introduced by the Green Industry Law, confirms that firms managing mandates still under the former regime must continue to apply portfolio-management-for-third-parties organisation and conduct rules, and notes that the applicable rule set is the one in force when the activity is performed. The updated doctrine further distinguishes arbitration mandates from the portfolio management investment service and reiterates that providing the latter, including to an insurer when managing part of its assets, triggers the corresponding investment-service requirements. Additional changes reword the simplified own-funds calculation table in Annex II of the activity programme guide to avoid confusion over corporate income tax deductions, and clarify when a firm may accept, as an ancillary activity, mandates to originate loans on behalf of a lender and/or manage loans granted by that lender outside the funds it manages. Firms covered by the new DORA documentation requirement have six months from publication of the revised doctrine to update their activity programme via the ROSA extranet.

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