The “Building 2025 Together” strategic plan shared by the Banque de France and the ACPR

To best perform its missions and stay the course in an uncertain environment, the ACPR shares the ambitions of the strategic plan drawn up by the Banque de France, “Building 2025 Together”. 

This strategic plan addresses seven challenges: 
•    shocks and shifts;
•    financial stability;
•    inflation;
•    climate change;
•    technological change;
•    social and local issues;
•    employer attractiveness.

The 2025 work programme is structured around 4 key work streams

Work stream 1: Ensuring the soundness of the financial sector in an uncertain political, economic and financial environment

In response to rising geopolitical risks, the ACPR will monitor international developments. The Authority will pay close attention to macro-financial contagion risks as well as to the assessment of the financial risks linked to market volatility and commodities. The ACPR will also examine the growth of the crypto-asset market and the associated risks.

The ACPR will closely monitor the exposure of financial institutions to the potential impacts of significant asset price volatility and interest rate spreads.

In an environment marked by changing interest rates, the ACPR will pay attention to net interest margin (NIM) developments in the French banking sector, as well as to French banks’ interest-rate risk management strategies. It will also monitor the impact of the macro-financial environment on payment institutions and electronic money institutions. In particular, the ACPR will delve into business model sustainability and to payment institutions’ ability to access finance.

Faced with rising corporate default rates and persistently high corporate indebtedness, the ACPR will continue to assess the quality of banks' assets along with their provisioning practices. It will also analyse their exposure to sectors or activities identified as vulnerable, including commercial real estate and leveraged finance.

In the banking sector, the ACPR and the Single Supervisory Mechanism (SSM) will cooperate within the framework of the stress test conducted every two years under the aegis of the European Banking Authority. This stress test will be an opportunity to capture risk developments for banks in a comprehensive manner.

In the insurance sector, the ACPR will continue to carefully monitor the management of interest-rate risk and asset/liability duration gaps. It will pay particular attention to those organisations most exposed to the economic climate, especially those specialising in construction insurance and credit insurance.

In the life insurance sector, the Authority will study changes in remuneration paid for 2024 and continue to monitor trends in inflows and their effects on insurers’ solvency and liquidity, including over the medium term. As regards non-life insurance, the ACPR will be looking into the way inflation is factored into insurers’ asset-liability modelling. 

Lastly, in order to take better account of the risks associated with interconnectedness across the financial sector, especially with non-banking financial institutions (NBFI), the ACPR is working, jointly with the Banque de France and the Autorité des marchés financiers (AMF –the French Financial Markets Authority), on the design of a mapping system that would allow for ongoing monitoring. The ACPR is also exploring, as a common effort with the Banque de France and the AMF, the feasibility of a pilot exercise involving a wide range of financial players. This explanatory exercise aims at better understanding both the nature of these risks and the way they spread; it will have no regulatory effect. 

Work stream 2: Refining our risk-based approach and simplifying the conduct of supervisory and regulatory work

The ACPR will step up its risk-based approach and simplify the conduct of supervisory work under its remit. Under this approach, which seeks to enhance efficiency, inspection work is tailored to reflect supervisory priorities, and adapted according to both the risk profile of the supervised institution concerned and the impact that institution’s failure would have. Innovation will continue to be applied to supervisory tools and to the development of tomorrow’s supervisory methods. To this end, the ACPR will strive to improve data quality and will endeavour to better leverage data.

ACPR staff will be fully mobilised working on simplifying the regulatory framework associated with the new European agenda. ACPR teams will be actively involved in negotiations on the draft PSD3 and FIDA Directives, the AI Regulation and the review of the macroprudential framework. The ACPR will also finalise other regulatory work currently underway, including on the implementation of the new framework applicable to credit servicers and the EMIR III Regulation. 

Work stream 3: Supporting the industry and proactively reducing structural vulnerabilities 

With regard to ongoing regulatory work at international level, the ACPR will continue to support banks in their implementation of the CRD6/CRR3 banking package and to keep track of the implementation of the Basel III framework, a key aspect of financial stability outside the European Union (including the United States). In the insurance sector, the Authority will also closely monitor the review of the Solvency II Directive and the provisions on the recovery and resolution of insurance and reinsurance undertakings. Lastly, the ACPR will make sure that financial players comply with the MiCA and DORA Regulations. 

As part of its commitment to fight climate change, the ACPR will continue its efforts to develop transition plans, which play a crucial role in financial institutions' definition of their strategy to tackle the climate challenge. The ACPR will endeavour to follow up on the findings derived from the stress test conducted in 2024 with French insurers (which included a focus on physical risks and the issue of insurability) and on the findings of the “fit for 55” exercise conducted with the entire European financial system. Striving to further improve the assessment and management of climate risks, the Authority will contribute to the work conducted by the EBA and the SSM to develop a climate stress test designed to assess the resilience of the EU banking sector on a regular basis, as well as its ability to support the achievement of the goals set by the Paris Agreement and implement the European transition strategy. 

The ACPR will follow the performance of supervised financial entities’ business models, more especially so in light of increasing digitalisation. The Authority will also monitor financial conglomerates and analyse the structure and resilience of their performance. In the insurance sector, the risks associated with outsourcing as well as with the presence of one or more intermediation layers will be closely monitored, notably to ensure that risk-bearers have adequate control over the entire value chain, as well as to assess the latter’s economic balance. 

Particular attention will continue to be paid to the risks associated with new technologies. The Authority’s primary focus will be the implementation of DORA with a view to better prevent cyber risk and strengthen control over ICT service providers. Concurrently, the ACPR will keep a close watch on operational risks (such as those associated with applications that rely on artificial intelligence, or those associated with poor data quality). 

Work stream 4: Strengthening the supervision of conduct risks and AML/CTF mechanisms

In line with its mandate to protect individual customers, the ACPR will continue to raise awareness of financial scams in partnership with the AMF and public authorities. Ensuring that proper regard is paid to customers’ best interests when designing and marketing banking and insurance products will remain a key concern. In the non-life sector, a thorough analysis will be conducted on low-value added insurance products, such as affinity products and para banking products. In the life insurance sector, the ACPR will keep working on its value for money report, considering the cost/return ratio of marketed unit-linked products, in line with the industry's commitments on the matter. In order to address greenwashing risks, the ACPR will continue to carry out controls over the way ESG (environmental, social and governance) preferences are integrated into the products and sales arguments of financial players.

Against the background of the establishment of the new Anti-Money Laundering Authority (AMLA), the ACPR will play an active part in the design the European supervisory model as well as in the final stages of AML/CTF regulations. The ACPR will gradually adapt its practices to support the new European model. It will represent France at the AMLA’s General Supervisory Board and will provide support the Paris financial centre during the setting up this new European structure. 
Concerning the supervision of AML/CTF mechanisms, the ACPR will finalise the roll-out of the new questionnaire adopted in 2022 and will prepare for the forthcoming AMLA reporting cycle, together with the Paris financial centre participants. The ACPR will widen the scope of its risk-based supervisory approach to include AML/CTF, as well as extend its supervision to the crypto-asset sector and disintermediated and decentralised finance, relying on transactional analysis tools. Lastly, the ACPR will conduct thematic and sector-specific investigations to monitor the development of emerging risks (including money laundering of the proceeds of fraud) and market trends, such as emerging banking-as-a-service models. 

Updated on the 27th of March 2025