Changes to the Eligibility of “Other AIFs” for Unit-of-Account Products in life insurance policies and retirement savings plans

As of May 6, 2026, funds classified as “Other AIFs” may no longer be newly listed as unit-linked products.

Investment vehicles already listed may nevertheless be maintained during a transitional period, provided that they commit to taking steps to comply with one of the approved regulatory frameworks. This change applies in particular to real estate investment companies (SCI) organized as “Other AIFs.”

The key deadlines are as follows:

• May 31, 2027: submission of compliance plans to the AMF, insurance companies, and the relevant PER managers;

• January 1, 2029: closure to new contributions and incoming transfers for investment vehicles that have not been brought into compliance, without forced liquidation of existing positions;

• January 1, 2032: a specific deadline applicable to certain fund-of-funds structures undergoing the ELTIF qualification process.

Management companies must identify the affected vehicles and determine, for each one, whether to initiate a transition to an approved regulated category or to organize its gradual closure to new inflows.

The custodian may be required to assist with the transformation of the affected vehicles, particularly by reviewing their governing documents and adapting their contractual and operational frameworks. Vehicles that have not been brought into compliance must, for their part, be managed as vehicles that are gradually being closed to new capital inflows.

It is therefore recommended to promptly conduct an inventory of the relevant funds, review their documentation, and coordinate efforts among management companies, custodians, insurers, and PER managers.

The teams at Société Générale Securities Services are available to assist their clients in analyzing the implications of this reform and supporting the necessary adjustments.