The ACPR presents its work program for 2025

On January 20, 2025, the Autorité de Contrôle Prudentiel et de Résolution (ACPR) unveiled its work program for 2025.

The ACPR’s 2025 roadmap is based on:

• the assessment of risks to the French financial system (conducted jointly with the Banque de France) included in the financial stability report published on December 19, 2024; and
• the supervisory priorities of the Single Supervisory Mechanism (SSM), the Single Resolution Board (SRB), the European Banking Authority (EBA), and the European Insurance and Occupational Pensions Authority (EIOPA).

This program is structured around four key areas this year:

• Key area 1: monitoring risk developments to ensure the stability of the financial sector in an uncertain political, economic, and financial environment.
• Key area 2: developing the regulator’s risk-based approach and undertaking efforts to simplify supervision and regulation.
• Key area 3: supporting the sector and proactively reduce structural vulnerabilities.
• Key area 4: strengthening the supervision of misconduct risks and of AML/CFT frameworks.

This particularly rich work program allows entities under the ACPR’s supervision to anticipate the topics that will soon receive special attention from the regulator (non-exhaustive list).

Specific Points of Attention by the ACPR for the Banking Sector

• The development of crypto-assets and associated risks.
• The exposure of financial institutions to potential impacts of high volatility for asset prices and interest rate spreads.
• The evolution of French banks’ net interest margin and interest rate risk management strategies.
• The sustainability of business models of payment institutions (including their access to funding) and electronic money institutions.
• The assessment of the quality of assets held by banks and their provisioning practices.
• Banks’ exposure to sectors/activities identified as vulnerable (such as commercial real estate and leveraged finance).
• The definition of financial institutions’ strategy in response to the climate challenge.
• The performance of financial entities’ business models in a context of increasing digitalization.
• Monitoring financial conglomerates (accompanied by an analysis of their structure and resilience of their results).

Specific Points of Attention by the ACPR for the Insurance Sector

• The management of interest rate risk and asset/liability duration gaps (particularly for players specialized in construction insurance or credit insurance).
• Regarding life insurance: variations in remuneration provided for 2024, changes in collection and their effects on insurers’ solvency and liquidity.
• Regarding non-life insurance: accounting for inflation in insurers’ liability modeling.
• The conclusions of the stress test conducted with French insurance bodies on physical risks and the question of insurability.
• The risks associated with outsourcing to one or more layers of intermediation in the sector.
• The design and marketing of low-value-added products in non-life insurance (particularly affinity and para-banking products) and price/quality ratio for life insurance products.

Some cross-sectoral points of attention by the ACPR

• Risks arising from interconnections within the financial sector (including those maintained with non-banking actors).
• The adaptation of controls depending on supervisory priorities, instiutions’ risk profile, and the impact of a supervised entity’s failure (development of future control methods through new supervisory tools).
• The improvement of data quality received by the ACPR and enhancing such data’s exploitation.
• The simplification of the regulatory framework in connection with the new European agenda.
• Risks associated with new technologies, the implementation of DORA to prevent cyber risks, and the supervision of IT service providers, as well as operational risks linked to the use of artificial intelligence applications and insufficient data quality.
• The prevention of financial fraud.
• Respecting customers’ interests in the manufacturing and marketing of banking and insurance products.
• Including ESG preferences in products and sales arguments of financial actors to prevent greenwashing risks.
• Completing the deployment of the new AML/CFT questionnaire and the future reporting of the European Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA).
• Money laundering risks in the crypto-asset sector and in disintermediated or decentralized finance.
• The evolution of fraud or market risks with the development of new models such as Banking-as-a-Service.

Furthermore, the ACPR has emphasized that it will be fully involved in negotiating new regulations (PSD3, FIDA, the AI Regulation) and implementing regulatory projects (credit managers, EMIR 3 Regulation, CRD6/CRR3, the revision of the Solvency 2 Directive, the recovery and resolution of insurance and reinsurance companies – IRRD, MiCA and DORA). It remains to be seen whether these regulatory projects will still be on the regulator’s agenda this year, in a context where the French government has recently expressed its intention to delay the implementation of certain regulations (e.g., market risk rules under Basel 3), or even to take a regulatory pause.