title: France — Conduct, Safeguarding & Promotions | World Payments Monitor canonical: https://payments.gi/jurisdictions/france/w1b/ publisher: Asymmetric Intelligence ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-06-23 Safeguarding for French PIs/EMIs follows PSD2/EMD2 segregation: client funds placed in a dedicated segregated account at a credit institution (or central bank / low-risk liquid assets), separate from the institution's own funds, with changes to the protection method requiring prior ACPR authorisation. Conduct/customer protection is an ACPR core mission under Art. L.612-1 CMF; the ACPR also supervises AML/CFT and business practices, issuing recommendations and positions (soft law). Horizon · 2026 (± a year) PSD3/PSR adoption and optional central-bank safeguarding method_Consultation · Tier 3 source_ Standing sub-brief · as of 26 June 2026 182 words · last cycle 2026-10-05 #### Conduct, Safeguarding & Promotions Safeguarding is the live W1b pressure point for French non-bank PIs and EMIs. Funds received on behalf of users must be placed in dedicated account(s) at a credit institution, separately from the institution's own funds — and the ACPR notes that some firms struggle to find a credit institution willing to provide such a segregated account. Any change to the protection method requires prior ACPR authorisation, decided by the Chairman of the College. Segregation availability is therefore a structural pressure point: bank de-risking of PI/EMI safeguarding accounts directly constrains non-bank market viability, distinct from the bank-PSP position which does not face the same external-account dependency. #### Outlook General safeguarding rules remain unchanged, but the incoming PSD3/PSR introduces an optional method of safeguarding funds in a central-bank account, with central banks not required to offer it; the ACPR is expected to update Instruction n.2019-I-22 accordingly. An optional central-bank safeguarding route could mitigate the bank de-risking problem for French PIs and EMIs if the Banque de France chooses to offer it — the key open question for this module into 2026. Periodic update · new data 2026-09-28 #### Conduct, Safeguarding & Financial Promotions France's PSD3/PSR reform, currently in its final legislative stage, reallocates unauthorised-payment liability onto payment service providers and platforms. Under the reform, PSPs must fully reimburse customers for unauthorised payments arising from identity-spoofing, provided the fraud is reported. This represents a conduct-side liability shift that moves financial exposure for a defined category of fraud from the customer to the PSP, changing the incentive structure for fraud-prevention investment. Ahead of the reform taking full effect, the ACPR, acting under Banque de France, is expected to prioritise fraud-prevention readiness, IBAN-verification infrastructure and incident-reporting capabilities in its early supervisory reviews under the new regime. This signals that early supervisory scrutiny will focus on operational readiness for the liability shift rather than on retrospective enforcement, suggesting PSPs have a defined but time-limited window to build the necessary infrastructure before supervisory attention intensifies. The practical effect for PSPs operating in France is a dual obligation: they must both build the technical capability (IBAN verification, incident reporting) that reduces the incidence of the fraud category now shifted onto them, and prepare for a supervisory review process that will test that capability directly. This is a conduct and safeguarding development rather than a licensing or market-access change; the underlying twin-peaks AMF/ACPR licensing architecture is unaffected by this reform. #### Outlook The near-term marker to watch is the point at which PSD3/PSR completes its final legislative stage and enters into force, at which point the reimbursement obligation and the associated ACPR supervisory reviews would become operative. PSPs' progress on IBAN-verification infrastructure and incident-reporting capability ahead of that point is the practical readiness indicator for this module. **1 earlier distinct update(s)** Periodic update · new data 2026-09-08 #### Conduct, Safeguarding & Financial Promotions France's payment-fraud statistics are this cycle's central conduct-relevant data point. The Banque de France's Observatoire de la sécurité des moyens de paiement reported payment fraud totalling €618.4 million across 3.7 million transactions in H1 2025. Within that total, authorised-push-payment fraud rose 37% year on year and now represents 40% of total fraud value, a substantial share shift that reflects the broader European trend of fraud migrating from card-present and card-not-present channels toward push-payment social-engineering scenarios that existing conduct rules were not originally designed to address. This Tier-1 statistical baseline is the empirical justification cited for the PSR's forthcoming conduct reforms, discussed further under Consumer Protection & APP Fraud. For conduct and safeguarding purposes specifically, the scale of the APP fraud increase signals that existing safeguarding and customer-communication practices at French PSPs are not keeping pace with the shift in fraud typology, creating a conduct-risk gap that the PSR's cascading-liability model is designed to close. The data covers H1 2025 and, as the most recent primary statistical source available this cycle, should be treated as the current baseline against which any future Banque de France reporting is compared. #### Outlook The next Banque de France Observatoire report will be the key marker for whether the 37% year-on-year APP fraud increase is a step-change or a continuing trend, and whether early PSP responses ahead of PSR implementation have begun to bend the curve. **Sources and findings (5)** 1. T1 [https://acpr.banque-france.fr/system/files/2025-01/20220315_new_payment_stakeholders_overview.pdf](https://acpr.banque-france.fr/system/files/2025-01/20220315_new_payment_stakeholders_overview.pdf) retrieved 2026-06-23 2. T1 [https://acpr.banque-france.fr/en/authorisation/banking-industry-procedures/other-changes-particulars/payment-institution-and-electronic-money-institution](https://acpr.banque-france.fr/en/authorisation/banking-industry-procedures/other-changes-particulars/payment-institution-and-electronic-money-institution) retrieved 2026-06-23 3. T1 [https://acpr.banque-france.fr/en/customer-protection/duties-acpr-and-actions-favor-customer-protection/customer-protection-principles-and-missions-acpr](https://acpr.banque-france.fr/en/customer-protection/duties-acpr-and-actions-favor-customer-protection/customer-protection-principles-and-missions-acpr) retrieved 2026-06-23 4. T3 [https://www.hsfkramer.com/notes/fsrandcorpcrime/2026-posts/the-new-eu-payments-rulebook-psd3-psr](https://www.hsfkramer.com/notes/fsrandcorpcrime/2026-posts/the-new-eu-payments-rulebook-psd3-psr) retrieved 2026-06-23 5. T3 [https://solent-avocats.com/en/the-powers-and-sanctions-of-thepr-what-you-need-to-know/](https://solent-avocats.com/en/the-powers-and-sanctions-of-thepr-what-you-need-to-know/) retrieved 2026-06-23