France is one of the largest alternative investment markets in Europe, but it does not get the attention it deserves from emerging fund managers. The regulatory framework is more sophisticated than most EU jurisdictions, but the upside is real: a streamlined notification process for professional funds, a limited partnership vehicle (the SLP) that was purpose-built to compete with Luxembourg, and a sub-threshold registration regime that lets smaller managers operate without full AIFM authorisation [1].
I work with managers across the EU on fund structuring and formation, and France keeps coming up as a jurisdiction where the setup process is faster and cheaper than people expect — provided you pick the right vehicle and understand how the AMF (Autorité des marchés financiers) thinks about oversight.
The sub-threshold registration option
Like every EU member state, France implemented the AIFMD sub-threshold exemption. If your total assets under management stay below EUR 100 million (including leverage), or below EUR 500 million for unleveraged funds with a five-year lock-up on redemptions, you can register with the AMF rather than seeking full authorisation [2]. The catch: all your investors must qualify as professional clients under MiFID definitions. No retail investors.
Sub-threshold managers are subject to lighter requirements on capital, reporting, and risk management compared to fully authorised AIFMs [2]. You still need to register with the AMF, comply with anti-money laundering rules, and maintain governance structures, but you avoid the full AIFMD compliance apparatus: no mandatory depositary, no detailed quarterly reporting to the regulator, and no formal risk management function from day one.
The trade-off is cross-border distribution. Sub-threshold managers do not get the AIFMD marketing passport. If you want to market your fund to professional investors in Germany, the Netherlands, or elsewhere in the EU, you need to use national private placement regimes country by country [3]. For managers focused on French LPs in the first fund, that is fine. For managers with cross-border ambitions from day one, full authorisation is worth considering even if you are below the thresholds.
The fund vehicles that matter
France has a long menu of fund structures, but for an emerging PE or VC manager, three are relevant:
- FPCI (Fonds Professionnel de Capital Investissement). The workhorse of French private equity. FPCIs are restricted to professional investors and do not require prior AMF authorisation — you file a notification within one month of creation [1]. This means you can have a fund operational in weeks, not months. The FPCI can be structured as a mutual fund (without legal personality) or as an investment company with variable capital [4].
- SLP (Société de Libre Partenariat). Introduced by the Macron Act in 2015 to compete with Luxembourg's SCS and the English limited partnership [5]. The SLP is a limited partnership with legal personality, which makes it familiar to international LPs used to common-law fund structures. Minimum commitment is EUR 100,000 per investor [5]. It follows the same notification-only regulatory path as the FPCI.
- SLPS (Société de Libre Partenariat Spéciale). A newer variant of the SLP without legal personality, modelled on the Luxembourg SCSp [4]. This matters for tax-sensitive international investors who need to avoid legal personality for treaty or withholding tax purposes.
For a first fund targeting French and European institutional investors, the SLP has become the default. It gives you limited partnership economics, familiar governance, and a regulatory process that does not require AMF pre-approval.
What AMF registration actually involves
Before you can manage a fund, you need an authorised management company (société de gestion). The AMF requires that your management company has its headquarters and effective management in France, has sufficient initial capital, and employs at least two full-time senior managers domiciled in the EU [1] [6]. The minimum share capital is EUR 125,000, with additional capital required above certain AUM thresholds [2].
The authorisation application must include a detailed programme of operations covering your investment strategy, organisational structure, compliance infrastructure, staffing plans, and risk management procedures [1]. The AMF reviews this in detail. Deficiencies in personnel qualifications are one of the most common reasons for delays — the regulator wants to see that your team has real investment management experience, not just advisory backgrounds [7].
For straightforward applications from experienced teams, AMF review takes four to eight weeks. First-time managers without established track records should expect longer. The AMF has indicated that the formal authorisation process does not exceed one month from receipt of a complete application [7], but getting to "complete" is where most of the time goes.
What you still have to do as a sub-threshold manager
Lighter regulation does not mean no regulation. Sub-threshold AIFMs in France must:
- Register with the AMF and pay an annual contribution of EUR 1,500 [8].
- Report to the AMF on assets under management so the regulator can monitor whether you are approaching the thresholds.
- Comply with French AML obligations, including full KYC procedures for all investors.
- Maintain proper governance with at least two senior managers, appropriate compliance processes, and auditable records for valuations and investor reporting.
- Restrict your investor base to professional clients under MiFID. If you onboard a non-professional investor, you lose sub-threshold eligibility.
You also need to monitor the AUM threshold continuously. If your assets cross the line, you must apply for full AIFM authorisation. Unlike some jurisdictions, France does not give you a long grace period.
The SLP in more detail
The SLP is worth understanding in more detail because it is the reason a lot of managers now stay in France instead of going offshore. Before 2015, managers who wanted a limited partnership structure had to go to Luxembourg or the Channel Islands. The SLP was designed to bring that business back to France [5].
An SLP operates as a société en commandite simple (limited partnership) with one or more general partners bearing unlimited liability and limited partners whose liability is capped at their commitment. The general partner is typically the management company or a dedicated GP entity controlled by the fund manager. The SLP has legal personality and appears in the French trade registry, which gives it standing to enter contracts, hold assets, and sue or be sued in its own name [5].
For international LPs, the key advantage is familiarity. The governance mechanics — capital calls, distribution waterfalls, advisory committees, key person provisions — work the same way they do in an English or Delaware LP. The EUR 100,000 minimum commitment keeps the investor base institutional, which simplifies administration and reporting [5].
How France compares to other EU jurisdictions
A few differences stand out when comparing France to Germany, Luxembourg, and other popular EU fund domiciles:
- Speed for professional funds. The notification-only path for FPCIs and SLPs means you can have a fund live within weeks. Luxembourg RAIFs are similarly fast, but German BaFin registration takes about a month [7].
- The SLP vs. Luxembourg SCSp. Both are limited partnerships designed for institutional capital. Luxembourg has more fund admin infrastructure and a longer track record. France has lower setup costs and a domestic LP base that prefers investing locally.
- Management company capital. France requires EUR 125,000 minimum share capital for the management company. Germany's sub-threshold regime has no comparable mandatory initial capital for the AIFM entity. Luxembourg requires EUR 125,000 for authorised AIFMs [2].
- Investor threshold. The EUR 100,000 minimum commitment for SLPs is higher than Germany's EUR 200,000 semi-professional investor threshold but serves a different purpose — it is a per-subscription minimum, not an investor classification [5].
- Passporting. Full AIFM authorisation in France gives you the marketing passport across the entire EU. Sub-threshold registration does not [3].
What is changing with AIFMD II
France must transpose AIFMD II into national law by April 2026 [6]. For sub-threshold managers, the most relevant changes concern loan origination funds and enhanced delegation requirements. If your fund originates loans, you will face additional organisational and risk management requirements even as a sub-threshold AIFM. The new reporting requirements to the AMF take effect from April 2027, giving managers a one-year transition period [6].
The AIFMD II also strengthens requirements around delegation — management companies will need to provide more detailed information about delegates, their resources, and the scope of any sub-delegation arrangements [6]. For managers who outsource portfolio management or operations to third parties, this means more documentation and more AMF scrutiny of those relationships.
How we help at Infra One
We work with emerging managers across Europe on fund formation and administration, and France is a jurisdiction we know well. Our team handles the management company setup, AMF registration process, fund structuring (whether FPCI, SLP, or SLPS), investor onboarding with automated KYC/AML, and ongoing fund administration including NAV calculations, investor reporting, and regulatory filings.
For managers who want to launch in France and later expand across the EU, we help plan the transition from sub-threshold registration to full AIFM authorisation so you are never caught unprepared. Our fund platform is built for exactly this trajectory.
If you are considering France for your fund launch, get in touch.
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