AMF · France

AMF MiFID II investment firm authorisation in France

Fintech Passport

June 21, 2026 · 5-min read

AMF MiFID II investment firm authorisation in France

A Prestataire de Services d’Investissement (PSI) authorised by the AMF is the French vehicle for MiFID II investment services — execution, portfolio management, advice, dealing on own account. The competent authority for the conduct and market-abuse side is the Autorité des Marchés Financiers (AMF); the prudential side runs through ACPR. The IFR Class 2 / Class 3 threshold test determines which prudential sub-regime applies. This piece walks through who grants what, what the application file needs to contain, and how the regime sits alongside the Spanish ESI.

1. Who grants and who supervises

French MiFID II investment-firm authorisation runs through a two-authority architecture:

AMF — conduct, market-abuse, marketing communications, customer-protection. The AMF is the primary authority for the authorisation itself, in collaboration with ACPR.
ACPR — prudential (capital, K-factors, large exposures), governance, ICT/DORA, AML framework.

The applicant submits a single file. The two authorities coordinate internally and issue a joint approval. Post-grant, conduct supervision sits with the AMF; prudential supervision with ACPR; AML is shared with TRACFIN.

2. Legal basis

Directive 2014/65/EU (MiFID II) — the services framework
Regulation (EU) 600/2014 (MiFIR) — markets and transaction reporting
Regulation (EU) 2019/2033 (IFR) and Directive (EU) 2019/2034 (IFD) — the investment-firm prudential framework
Code monétaire et financier and AMF Règlement Général — French implementation
ESMA guidelines and AMF doctrines — operational rules

3. MiFID II services catalogue in France

Annex I MiFID II lists eight services. The PSI application specifies which the firm will provide:

Reception and transmission of orders (réception-transmission d’ordres)
Execution of orders for the account of clients (exécution d’ordres pour compte de tiers)
Dealing on own account (négociation pour compte propre)
Portfolio management (gestion de portefeuille pour compte de tiers)
Investment advice (conseil en investissement)
Underwriting and placing of financial instruments (prise ferme; placement garanti ou non garanti)
Operation of multilateral trading facilities (MTF) and organised trading facilities (OTF)

Ancillary services — custody, currency exchange linked to investment services, investment research — are listed in Annex II and can be added to the authorisation.

4. The IFR classification — Class 1, 2 or 3

Same EU framework as for Spanish investment firms:

Class 1 — largest investment firms with bank-like risk profiles; treated as banks under CRR / CRD
Class 2 — full IFR/IFD regime; default for most authorised firms
Class 3 — small and non-interconnected firms (SNI); lighter regime

The classification is run at the firm’s reference date and can change year-to-year. ACPR runs the prudential supervision under whichever class applies.

5. Capital floors

IFR Article 9 sets the minimum permanent own-funds requirement based on services:

€75,000 — for firms not authorised to hold client money or deal on own account, providing limited services
€150,000 — for firms authorised to hold client money or deal on own account on a matched-principal basis
€750,000 — for firms dealing on own account on an unmatched-principal basis and the largest firms

Ongoing own funds must be the higher of the floor, the fixed-overheads requirement and the K-factor requirement (Class 2 only).

6. What goes in the dossier

The PSI dossier mirrors the EME / EP file structure with investment-services specifics:

Programme of operations — the MiFID II services, client segments, geographies, financial instruments in scope
Business plan — three-year projections, capital, profitability under stress
Governance map — dirigeants effectifs, key function holders, with fitness-and-properness for each (the AMF runs interviews on conduct-side appointments; ACPR on prudential-side)
Internal-control framework — risk, conformité, contrôle permanent, contrôle périodique, with the MiFID II conflict-of-interest, best-execution and suitability frameworks
ICT and operational-resilience framework aligned with DORA
Capital plan — initial own funds, ongoing methodology, K-factor calculation where Class 2
AML / CTF programme with designated déclarant TRACFIN and correspondant TRACFIN
Conduct framework — suitability and appropriateness, best-execution policy, conflicts and inducements, complaint handling
Transaction-reporting framework — MiFIR Article 26 reporting to AMF
Outsourcing register
Shareholder structure — direct and indirect, with fitness-and-properness on qualifying shareholders

7. Realistic timing

Statutory review under MiFID II is six months for complete files. End-to-end with pre-application engagement and feedback rounds: nine-to-twelve months for a first-time applicant. Pre-application meetings with AMF and ACPR are standard.

8. What switches on at grant

MiFIR Article 26 transaction reporting to AMF (daily)
IFR / IFD prudential reporting via SURFI + COREP-IFR
AMF conduct returns — complaints, suitability outcomes, best-execution metrics
AML obligations under CMF Articles L.561-1 onwards — TRACFIN reporting
Passporting notifications where services extend to other member states — see branch vs FoS

9. FAQ

Why are two authorities involved?

French law splits investment-firm supervision between conduct (AMF) and prudential (ACPR). Other EU member states sometimes use a single authority. The French split is a structural choice that affects which questions get asked at which point of the file review.

Is the application filed with AMF or ACPR?

A single dossier is submitted; both authorities receive it through the joint intake procedure. The applicant deals with both during the feedback rounds.

Can I offer crypto-asset services under a PSI licence?

For services that fall within MiFID II financial instruments (security tokens, tokenised securities) — yes. For crypto-assets within MiCA scope — a separate CASP authorisation is required.

How does client money work in France under MiFID II?

Client money rules under MiFID II Article 16 — segregated in dedicated accounts, reconciled daily, with the segregation arrangement evidenced in the dossier. ACPR is detailed on the segregation mechanics.

What’s the role of the AMF Doctrine?

The AMF Doctrine consolidates the AMF’s policy positions on investment-services topics. Cited frequently in the dossier — the firm must demonstrate awareness and application of the relevant doctrine pieces, particularly on marketing communications, suitability and inducements.

How is conduct supervised post-grant?

The AMF runs thematic inspections and ad-hoc enquiries on conduct. The complaints reporting feeds into the AMF’s médiateur process and supervisory ratings. See our conduct & complaints piece for the broader picture.

10. What to do, today

Run the IFR Class 2 / Class 3 threshold test against your business plan.
Engage AMF and ACPR in coordinated pre-application meetings.
Build the dossier in French; AMF and ACPR engage in French.
Build the MiFIR transaction-reporting layer alongside the application; it goes live on day one.
Plan the post-grant catalogue (SURFI, COREP-IFR, MiFIR transaction reporting, AML, conduct) before submission.