1. Status of implementation
  2. National deviations
  3. Loan origination regime
  4. Regulatory guidance

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France
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Status of implementation

France has not yet adopted its AIFMD II implementing legislation. No draft bill or ordonnance has been formally published as of early 2026. According to French authorities (Banque de France, HCJP and AMF), the transposition is ongoing and must be completed by 16 April 2026. France is expected to implement AIFMD II through amendments to the Code monétaire et financier and the Règlement général de l’AMF. The transposition is expected to be largely faithful to the Directive, without major structural changes. AMF doctrine already anticipates transitional periods for certain measures, such as liquidity tools.

National deviations

At this stage, no confirmed national deviations have been formally announced. The HCJP has recommended a faithful transposition and the removal of any conflicting French provisions. France already has a relatively strict framework for AIFs, meaning that a number of AIFMD II provisions are broadly aligned with existing practice. Some areas may still give rise to French-specific clarifications once the implementing measures are published, in particular to ensure consistency between AIFMD II and existing French rules regarding:

  • The activities of management companies (sociétés de gestion).
  • The applicable supervisory framework.
  • The articulation between EU-level requirements and existing French regulatory concepts or authorisation regimes.

Loan origination regime

AIFMD II leaves it to the discretion of Member States to determine whether, for reasons of public interest, AIFs should be prohibited from granting loans to consumers. In France, the Directive is expected to clarify and organise loan origination by French and foreign AIFs, potentially relax aspects of the monopole bancaire, and maintain national discretion regarding consumer lending. France may maintain restrictions on lending to consumers for public-interest reasons, although no final position has yet been formally adopted.

Regulatory guidance

As of early 2026, the AMF has not yet issued detailed implementation guidance on AIFMD II. In particular, there is no comprehensive circular or Q&A setting out supervisory expectations. Aside from targeted updates to its doctrine, notably in relation to liquidity management tools, the regulator has so far limited itself to high-level communications. More detailed guidance is generally expected as France moves closer to the April 2026 transposition deadline.