AMF France — Autorite des Marches Financiers

Overview

The Autorite des Marches Financiers (AMF) is France’s financial markets regulator, overseeing approximately EUR 2.1 trillion in fund assets managed by French-regulated asset management companies. The AMF is recognised as one of the strictest MiCA interpreters alongside Austria’s FMA and Italy’s CONSOB, and has called for stronger EU-level oversight to prevent jurisdiction shopping. The AMF administers France’s blockchain ordre system for fund share registration — the first national framework in the EU explicitly permitting DLT-based fund share recording — and oversees the implementation of MiCA CASP authorization. For 2026, the AMF has set priorities including launching a consultation on tokenisation projects in the asset management sector and contributing to discussions with the Banque de France and French Treasury. The AMF adopted ESMA’s crypto market abuse guidelines in July 2025, and the DASP-to-MiCA transition deadline is July 1, 2026.

The Blockchain Ordre System

France’s Ordonnance No. 2017-1674 (December 2017) and its implementing decree (December 2018) created the “blockchain ordre” — a legal framework permitting the registration of unlisted securities, including fund shares, on a distributed ledger. This framework, administered by the AMF, was the first EU-level authorization for DLT-based securities registration and predated the EU DLT Pilot Regime by over five years.

The blockchain ordre framework permits: registration of fund shares (parts de fonds) on a blockchain-based shared electronic recording system (dispositif d’enregistrement electronique partage, or DEEP); transfer of fund shares through DLT-based transactions without intermediary involvement; and recording of ownership rights with the same legal force as traditional registrar entries.

For fund managers, the blockchain ordre eliminates the need for a centralized registrar for fund share ownership — the DLT itself serves as the legal record. This reduces operational costs associated with traditional share registration and enables near-instant transfer of fund ownership. Several French fund managers, including Societe Generale’s FORGE subsidiary and BNP Paribas, have issued tokenized fund shares under the blockchain ordre framework.

MiCA CASP Authorization Role

The AMF serves as the primary MiCA competent authority for France, processing CASP (crypto-asset service provider) authorization applications. As of March 2026, the AMF has received over 100 CASP applications and authorized approximately 30 entities — including digital asset custodians, trading platforms, and advisory services that support tokenized fund operations.

For tokenized fund products, the AMF’s MiCA authorization function is particularly important because it determines which service providers — custodians, transfer agents, and settlement infrastructure operators — can legally provide services for tokenized fund operations in France and, through MiCA passporting, across the EU.

The AMF has published guidance on MiCA authorization requirements, including specific expectations for: operational resilience and business continuity planning for DLT-based service providers; cybersecurity standards for entities handling tokenized fund assets; and conflicts of interest management for CASPs providing multiple services (custody, trading, and advisory) to tokenized fund products.

MiCA Full Enforcement and AMF Preparedness (July 2026)

MiCA’s full enforcement date of July 2026 represents a transformative moment for the AMF’s supervisory operations. From that date, every crypto-asset service provider operating in France — or passporting into France from another EU member state — must hold CASP authorization under MiCA’s harmonized framework. The AMF has been preparing for this transition since MiCA’s publication in June 2023, building dedicated supervisory teams and IT infrastructure to handle the expected surge in authorization and ongoing supervision workloads.

The AMF’s existing experience with France’s earlier PSAN (Prestataires de Services sur Actifs Numeriques) registration regime gives it a head start relative to NCAs in member states that lacked pre-MiCA crypto regulatory frameworks. Approximately 75 entities held PSAN registration in France before MiCA’s transitional provisions took effect, and these entities must convert to full MiCA CASP authorization by July 2026. The AMF has published a detailed transition timeline, requiring PSAN-registered entities to submit MiCA applications no later than March 2026 to ensure authorization by the enforcement deadline.

For tokenized fund service providers specifically, the AMF has identified three priority authorization categories: digital asset custody services (for custodians holding tokenized fund shares and underlying digital assets), operation of a trading platform for crypto-assets (for venues listing tokenized fund shares), and crypto-asset transfer services (for entities facilitating tokenized fund share transfers between investors). The AMF’s MiCA implementation guidance specifies the documentation, capital, and operational requirements for each category.

DORA Compliance and Operational Resilience

The Digital Operational Resilience Act (DORA), applicable from January 2025, imposes additional requirements on financial entities supervised by the AMF — including fund managers and CASPs operating tokenized fund infrastructure. DORA requires ICT risk management frameworks, incident reporting to the AMF within specified timeframes, digital operational resilience testing (including threat-led penetration testing for systemically important entities), and management of ICT third-party provider risk.

For tokenized fund operations, DORA’s requirements interact with MiCA’s operational resilience standards. The AMF has published guidance clarifying that fund managers using blockchain platforms for tokenized fund operations must treat blockchain network providers, smart contract audit firms, and oracle network providers as critical ICT third-party service providers subject to DORA’s concentration risk management requirements.

French Fund Market and Tokenization Potential

France’s fund industry manages approximately EUR 2.1 trillion in assets, the third-largest in the EU after Luxembourg and Ireland. French-domiciled funds include: fonds communs de placement (FCPs — contractual funds); societes d’investissement a capital variable (SICAVs — open-ended investment companies); and organismes de placement collectif en valeurs mobilieres (OPCVM — the French implementation of UCITS).

The French fund market has several characteristics that favor tokenization adoption: a strong domestic fintech ecosystem (Station F, French Tech), major banks with advanced DLT capabilities (Societe Generale FORGE, BNP Paribas Securities Services, Credit Agricole CIB), and political support for financial innovation under the “French Tech 2030” agenda.

The Paris financial center’s tokenization pipeline includes several notable initiatives beyond SG-FORGE. BNP Paribas Securities Services has developed a tokenized fund administration platform supporting on-chain NAV calculation for French-domiciled funds. Credit Agricole CIB, through its CACEIS subsidiary, has invested in DLT-based transfer agent capabilities that integrate with the blockchain ordre framework. Euronext Paris, regulated by the AMF, has explored listing tokenized fund shares under the DLT Pilot Regime, which would create a regulated secondary market for tokenized French funds.

Coordination with ESMA and Peer Regulators

The AMF is a member of ESMA’s Board of Supervisors and actively participates in ESMA’s work on tokenized fund regulation. The AMF’s early experience with the blockchain ordre framework has given it credibility and influence within ESMA on DLT-related policy questions. The AMF has contributed to: ESMA’s technical standards for tokenized fund valuation; the DLT Pilot Regime implementation guidance; and MiCA implementing technical standards for CASP authorization.

The AMF also coordinates bilaterally with BaFin (Germany), the CSSF (Luxembourg), the Central Bank of Ireland, and the FCA (UK) on cross-border tokenized fund supervision. The SEC vs. ESMA comparison examines how the AMF’s position within ESMA affects the EU’s overall approach to tokenized fund regulation relative to the US.

Societe Generale FORGE: A Case Study

Societe Generale’s blockchain division, SG-FORGE (now SG-FORGE SA with MiCA CASP authorization), represents the most advanced institutional deployment of tokenized securities in France. SG-FORGE has issued digital bonds on public blockchains (Ethereum and Tezos), with settlement in euro-denominated CBDC through the Banque de France’s DL3S platform.

SG-FORGE’s activities are directly supervised by the AMF and provide operational evidence that informs the AMF’s regulatory approach to tokenized fund products. The issuance of SG-FORGE’s EUR 10 million digital bond in April 2023 — settled in wholesale CBDC on a public blockchain — demonstrated that the AMF’s regulatory framework can accommodate fully on-chain tokenized securities operations while maintaining investor protection and market integrity standards.

For tokenized fund products, SG-FORGE’s experience suggests that French regulation can accommodate: fund share issuance on public blockchains; settlement in digital central bank money through ECB wholesale CBDC trials; and smart contract-based compliance enforcement using permissioned token standards (ERC-3643).

ERC-3643 and Permissioned Token Standards

France has emerged as a center of expertise for permissioned token standards — particularly ERC-3643 (formerly T-REX), an Ethereum token standard developed by French company Tokeny Solutions. ERC-3643 embeds identity verification and compliance rules directly into the token’s smart contract logic, enabling automated enforcement of investor eligibility, transfer restrictions, and regulatory hold periods. The AMF has indicated acceptance of ERC-3643 as a compliance mechanism for tokenized fund shares distributed under French regulation, provided the underlying identity verification satisfies EU anti-money laundering requirements.

ERC-3643’s adoption in France demonstrates how permissioned token architectures can satisfy regulatory requirements while operating on public blockchains — a model that other EU member states and the CSSF in Luxembourg are examining as a template for their own tokenized fund frameworks. The authorized participant blockchain models analysis examines how permissioned token standards affect creation-redemption mechanics for tokenized ETFs.

Impact on Fund Sponsors

Fund sponsors considering France as a domicile for tokenized fund products benefit from: the blockchain ordre framework providing explicit legal authority for DLT-based share registration; a large pool of French-regulated service providers with CASP authorization; Euronext Paris as a potential listing venue for tokenized ETFs under the DLT Pilot Regime; competitive fund domiciliation costs relative to Luxembourg and Ireland; and the AMF’s demonstrated willingness to engage with innovative fund structures.

Fund sponsors should file pre-application consultations with the AMF’s Direction de la Gestion d’Actifs (asset management directorate) before commencing formal registration. The AMF publishes guidance and authorization requirements at amf-france.org. The regulatory filing guide details AMF filing procedures for tokenized fund products.

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