{{ languageVal }}
  • English

Industry Updates

Amended AMF Policy on Collective Investments Incorporating ESG / Non-financial Criteria

31 Jul 2020

On 16 July 2020, the AMF announced that it has amended its policy recommendation DOC-2020-03, which sets out information related to non-financial criteria such as ESG, that may be disclosed by French collective investments and foreign UCITS authorised for marketing in France.

Further information in respect of this policy recommendation can be found in our Q1 2020 Market Update, which is available here.

As part of the amended policy recommendation, the AMF has added annexes to the instructions relating to products that use non-financial criteria as a central theme in their KIID and / or marketing materials.

For applicable products, the annexes include specific forms which should be completed in the following instances:

(a) authorisation processes;
(b) preparation of fund documentation such as KIIDs and Prospectuses; and
(c) periodic reporting for French and foreign UCITS marketed in France.

It is worth noting that the AMF has stated that foreign UCITS using non-financial criteria as a central theme in their marketing documents should complete a form before notifying the fund for marketing in France through the UCITS passport.


It is possible to include non-financial criteria in a KIID without triggering the full application of the policy recommendation.

In order to do so, the non-financial criteria language must be concise and balanced and should only be included in the 'Other Information' section of the KIID.

Marketing materials may include concise details (as defined by the AMF) regarding non-financial criteria without triggering the policy recommendation.


For existing UCITS which were marketed in France prior to 11 March 2020, the deadline for updating their KIIDs and / or marketing materials has now been extended until 10 March 2021.

Any further UCITS marketed in France between 11 March 2020 and 27 July 2020 have until 30 September 2020 to implement the new rules.

For the avoidance of doubt, newly passported UCITS are required to comply with these rules immediately.

How the Maples Group can Help

Maples Group Global Registration Services ("Maples Group GRS") can assist UCITS in the completion and filing of the forms required by the AMF.

Maples Group GRS supports UCITS  and AIFMs1 in their multi-market distribution strategies by providing an integrated global network of experts, coordinated by a dedicated central team supporting all legal and regulatory aspects governing the cross- border marketing of investment funds on both a private placement and public offer basis.

Further Information

If you would like further information, please liaise with your usual Maples Group contact or either of the below. 

Print Ready Version

Related Services

Funds & Investment Management

Advising on the laws of the BVI, the Cayman Islands, Ireland, Jersey and Luxembourg, our global Funds & Investment Management team provides expert legal advice on every aspect of the life cycle of an investment fund including set up, management and investment across a broad range of fund structures and management entities.  

Global Registration Services

Our global Funds & Investment Management team offers cross-border fund registration and ongoing maintenance services to funds domiciled in the BVI, the Cayman Islands, Ireland, Jersey and Luxembourg through the EEA passport and / or non-EEA registration / national private placement regimes in over 70 global locations.  Our core services include market intelligence, market entry, i.e. pre-marketing notifications under AIFMD for EU and non-EU AIFM, EEA 'Passport' registration, global private placement, local agent selection, managing the translation of fund documents into multiple languages for filing purposes, maintenance of ongoing reporting and filing obligations. 

ESG Policies & Frameworks

Our team of highly experienced global lawyers work with leading investment managers and institutional investors in Europe, America and Asia to implement ESG policies and frameworks into their operational infrastructure. This exposure provides us with a 360-degree perspective as to how fund industry leaders are approaching ESG and we are therefore very well-positioned to action customised mandates for services incorporating ESG for managers of all sizes and across the spectrum of strategies.