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The publication of Decree No. 2026‑341 of April 30, 2026 marks a decisive shift in the regulatory treatment of French so-called “Autres FIA” (or “other alternative investment funds”, a sub-category of AIFs which are not specifically regulated under the French Monetary and Financial Code), for the purposes of unit‑linked life insurance and pension/retirement savings products (PER).
After several months of uncertainty surrounding both its timing and scope, the decree significantly narrows the universe of funds eligible for distribution through these savings wrappers, reflecting the authorities’ growing scrutiny of AIFs such as the “Autres FIA” that are not subject to dedicated investment rules.
The new framework definitively excludes Autres FIA from future eligibility for life insurance and PER products, while introducing a transitional regime for funds already listed under these savings vehicles, subject to strict conditions and a demanding compliance timeline extending to 2027 and 2029.
In practice, the decree raises complex strategic, legal and operational questions for asset managers and insurers alike, including the choice of an appropriate regulatory regime, the scope of the required amendments to fund documentation, and the treatment of liquidity and “hybrid” structures.
In this article, our lawyers analyse the key provisions of the decree, highlight the main areas of uncertainty and set out the practical implications for market participants navigating this new regulatory landscape.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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