Conduct and complaints reporting to ACPR — the French framework

France’s conduct-side supervisory reporting runs on its own track, separately from the prudential and AML cycles. ACPR (for credit institutions, EMEs and EPs) and the AMF (for investment firms and CASPs) collect structured data on customer complaints, mediator interactions and conduct outcomes. The DGCCRF — the French consumer-protection authority — sits alongside on broader consumer-law matters. Each of the three authorities has its own intake and its own cadence. This piece walks through who reports what, where, and how the cycle fits next to the rest of the supervisory catalogue.

1. Who supervises conduct in France

• ACPR — conduct supervision for credit institutions, EMEs, EPs, branches of foreign PSPs, and certain insurers. Operates the Pôle commun ACPR-AMF for cross-sectoral issues.
• AMF — conduct supervision for investment firms (PSIs), CASPs, asset managers, financial advisers
• DGCCRF — Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes — the French consumer-protection authority. Engages on broader consumer-law matters that touch financial services (advertising, contractual fairness, marketing practices).
• Médiateur de l’AMF / Médiateur de l’ACPR — independent dispute-resolution mechanisms operated by the supervisors

2. Legal basis

• Code monétaire et financier — conduct rules and reporting obligations for credit institutions, EMEs, EPs
• Code de la consommation — French consumer-protection rules layered on top of EU consumer-credit and unfair-terms directives
• AMF Règlement Général and Doctrines — investment-services conduct rules and reporting
• ACPR notices and recommendations on complaints handling, conduct outcomes, and customer-protection measures
• EU consumer-protection regulations (notably the Consumer Credit Directive recast and PSD2 conduct rules)

3. Complaints reporting

Typical fields per complaint:

• Customer category — consumer, professional
• Product or service category
• Channel of receipt
• Date received and date resolved
• Outcome — upheld, partially upheld, rejected, mediated
• Whether the customer escalated to the Médiateur
• Whether any remediation payment was made

Submission is annual or semi-annual depending on the supervisor and the firm size. The structured data feeds ACPR’s and AMF’s supervisory ratings.

4. The mediator regime

Both ACPR and the AMF operate Médiateur services — independent dispute-resolution mechanisms accessible to retail customers after the firm’s internal complaint-handling has been exhausted. The Médiateur:

• Receives the customer’s complaint after the firm has had a defined window to resolve (typically two months for consumer complaints)
• Investigates and proposes a non-binding resolution
• The firm has a defined window to accept, reject or counter-propose
• Outcomes feed the supervisor’s conduct data — patterns of adverse opinions are a supervisory signal

Médiateur outcomes are also published in summary form in annual reports.

5. DGCCRF — the consumer-protection overlay

DGCCRF is the French market-surveillance authority for consumer protection across all sectors, including financial services. Its role overlaps with — but does not replace — ACPR and AMF supervision. DGCCRF interventions tend to cluster around:

• Advertising practices and price transparency
• Unfair contractual terms (clauses abusives)
• Consumer-credit advertising and pre-contractual information
• Cross-selling and unsolicited offers
• Distance-selling rules under the French Code de la consommation

DGCCRF can impose its own administrative sanctions independently of ACPR or AMF. The two regimes coexist; firms in scope of financial-services supervision face both. Coordination between ACPR and DGCCRF runs through the Pôle commun arrangement on cross-cutting matters.

6. Beyond complaints — conduct outcomes

Supervisors collect outcome data beyond raw complaint counts:

• Suitability and appropriateness (MiFID II / MiCA) — sample assessments of customer-questionnaire outcomes
• Best execution — venue analysis, execution-quality metrics
• Marketing communications — sample review for compliance with the marketing-consistency rules under MiCA, MiFID II and the AMF Doctrine
• Fee transparency — alignment between advertised fees and actual charges
• Vulnerable-customer outcomes — increasingly featured in ACPR thematic inspections

7. Cadence and channel

8. Reconciliation

The complaints submission must reconcile against the firm’s internal case-management system. Supervisors sample underlying cases during inspections — a complaint logged internally but missing from the supervisory submission is a finding. The reverse — a submission containing complaints not in the internal log — is also a finding.

9. FAQ

10. What to do, today

• Build the complaints case-management system around the structured fields the supervisor wants — category, channel, resolution time, outcome — not free text.
• Reconcile the supervisory submission against the internal case log every cycle.
• Track Médiateur request patterns separately — escalation volume is itself a supervisory signal.
• Coordinate conduct reporting with AML and prudential cycles so a single audit trail covers all three for any inspection.
• Watch the PSD3 / PSR package — the conduct provisions are being refreshed and the reporting framework will be updated accordingly.

Related: EMI licence in France · AMF MiFID II investment firm · Conduct and complaints reporting Spain (DCMR)