AMF insider declarations explained: how French dirigeant filings work

Who must declare

France did not write its own insider-dealing disclosure regime. Since July 2016 the rules come straight from Article 19 of the EU Market Abuse Regulation (MAR), which applies directly in every member state. What French law adds is the plumbing: Article L. 621-18-2 of the Code monetaire et financier designates the AMF as the recipient, and Articles 223-22 A to 223-26 of the AMF General Regulation (RGAMF) set the national parameters.

The population is the MAR one:

• Persons discharging managerial responsibilities (PDMR), in French practice "dirigeants": members of the board or supervisory bodies, plus senior executives who are not board members but have regular access to inside information and the power to take managerial decisions affecting the company's prospects.
• Persons closely associated with them: a spouse or equivalent partner, a dependent child, a relative sharing the household for at least a year, and any legal person, trust or partnership managed by, controlled by, or set up for the benefit of one of the above.

The AMF states it plainly: persons having management responsibilities must report to the AMF the transactions they perform on the financial securities of the company in which they perform their functions, and persons closely related to them must do the same. A holding company controlled by a CEO files under the same regime the CEO does, which is why French filings frequently show corporate vehicles rather than natural persons.

What transactions get reported

The transaction scope is MAR Article 19 plus the detailed list in Delegated Regulation 2016/522: purchases and sales, subscriptions to capital increases, acceptance and exercise of stock options and the disposal of the resulting shares, pledges, securities lending, gifts and donations made or received, inheritances, transactions executed under discretionary mandates, and derivative or fund exposure linked to the issuer's securities. Fund units are exempt only when exposure to the issuer stays at or below 20 percent of the fund's assets and the PDMR does not know the composition.

France adds one obligation of its own. Under RGAMF Article 223-26, the annual management report must recap the transactions declared by dirigeants and their close associates during the financial year. The same trades therefore surface twice: once in the AMF database within days, once in the annual report months later.

The threshold, and its December 2025 jump

MAR lets each national authority set a de minimis floor below which no declaration is due. France had long used the option to sit above the EU baseline: RGAMF Article 223-23, in the version in force from 20 November 2017 to 27 December 2025, exempted transactions as long as their cumulative amount for the current calendar year did not exceed EUR 20,000.

The EU Listing Act (Regulation 2024/2809, applicable from 4 December 2024) raised the EU baseline to EUR 20,000 and rewrote Article 19(9) to let national authorities go up to EUR 50,000. France took the full headroom: the AMF amended Article 223-23 to EUR 50,000, homologated by an arrete of 4 December 2025 and published in the Journal officiel on 26 December 2025. Small trades that would have hit the tape in 2025 stay dark in 2026.

The three trading day deadline

The dirigeant or close associate must notify both the issuer and the AMF promptly, and no later than three trading days after the transaction. That is the MAR three-business-day rule as the AMF phrases it.

On the publication side, MAR Article 19(3) as amended gives the issuer two business days from receipt to make a notification public. In France the point is largely moot: the AMF itself publishes the declarations it receives, so the filing and the public record run through the same regulator. One caution for readers of older material: pre-MAR French guidance allowed five business days, and some third-party guides still repeat that number. The current rule is three.

Worst realistic case, a trade is public five business days after execution. The US Form 4 clock is faster (two business days), Canada's SEDI allows five calendar days, so France sits in the middle of the pack.

Where filings are published

Two systems get confused constantly, and only one of them holds directors' dealings:

• BDIF (bdif.amf-france.org) is the AMF's decision and financial disclosure database. Declarations des dirigeants are published there, searchable by company and period, free, with no accreditation, with records going back to 1997. Archives predating 2009 are also available on data.gouv.fr.
• info-financiere.gouv.fr is France's central storage mechanism (OAM) for regulated information under the Transparency Directive, operated by DILA. Annual reports and press releases live there. Directors' dealings do not.

The filing channel is separate from both: declarations are submitted through ONDE, the AMF's extranet for issuer filings. ONDE is the input, BDIF is the output, and only BDIF matters to an outside reader.

How to read an AMF declaration

Every declaration follows the EU standard template of Implementing Regulation 2016/523 and carries an AMF reference number in a recognisable format, for example 2026DD1095929 (year, "DD" for declaration des dirigeants, then a serial). The template fields:

Field 2 deserves the first look: it says whether the filer is the dirigeant or a related party, and whether the document amends an earlier one. Field 4b carries the economic meaning. The AMF's interpretive doctrine sits in its Q&A DOC-2006-14 on executives' and close relations' transactions and in guide DOC-2016-08.

Interpretation traps

The threshold is a floor, not a cap

EUR 50,000 is an exemption below the line, not a reporting cap. The test runs on the cumulative gross amount of all transactions in the calendar year, without netting purchases against sales. Once the running total crosses the threshold, every subsequent transaction must be declared, however small. A EUR 500 trade in November can be perfectly reportable.

The 2026 series break

Raising the floor from EUR 20,000 to EUR 50,000 mechanically removes small filings from the record. French declaration volumes drop from 2026 onward for regulatory reasons, not because insiders stopped trading. After Germany's equivalent move, BaFin reported roughly one third fewer notifications. Any comparison of French filing counts across the 2025/2026 boundary is apples to oranges.

30-day closed periods

MAR Article 19(11) bars PDMR from trading during the 30 calendar days before the announcement of an interim or year-end financial report. Exemptions exist (severe financial difficulty, employee schemes, and since the Listing Act a wider set of no-active-decision cases such as corporate actions and inheritances), but the practical effect is that French insider activity clusters just after results. A burst of buying the week after earnings is the calendar at work, not necessarily a coordinated signal.

Zero-price rows

Gifts, donations, inheritances and share awards are all notifiable and all print at a zero or nil price. These are non-market transactions, not data errors, and they say nothing about what the insider would pay for the stock.

Option exercises come in pairs

An exercise at the strike price and the subsequent sale of the resulting shares are two separately notifiable transactions for one economic event. Counting both rows as independent decisions double-counts a single monetisation of compensation.

How insiders-trades.com tracks the AMF

The AMF was the first regulator this site ever ingested, and the French feed remains one of the deepest in our dataset. We pull declarations des dirigeants from the BDIF database, keyed on the AMF reference IDs (the 2026DD... numbers), then parse the PDF notification bodies to extract role, instrument, price and volume, since the substance of a French filing lives in a PDF rather than structured fields. Roles are normalised into the same taxonomy we apply across 28 regulators, so a directeur general and a CEO land in the same bucket.

Browse the live output on the French market hub, or start from a company page such as TotalEnergies or Tikehau Capital. For a sense of what a prolific French filer profile looks like, including holding-company vehicles filing as closely associated persons, see Antoine Flamarion, co-founder of Tikehau.

For the EU-level rules France implements, see our MAR Article 19 guide, and for how the rest of the world compares, the insider disclosure rules by country index.