In July 2019, the two authorities announced the implementation of an annual monitoring and evaluation system for the commitments made by banks, insurers and asset management companies with regard to climate issues. After publishing an extract on coal policies at the end of October 2020, they published their conclusions on all the commitments on 18 December 2020. At the end of this first evaluation exercise, the French authorities pointed out the growing mobilisation of the financial sector in favour of the fight against climate change and, in particular, the objective of decarbonising portfolios. More than 300 individual or collective commitments were recorded at the end of 2020. On the basis of these observations, the ACPR and the AMF have identified areas for improvement and have formulated a series of recommendations for market participants. In regards to general recommendations, they wish to facilitate the traceability and reliability of commitments, strengthening the effectiveness of commitments by defining quantified targets, a clearly defined timetable and progress monitoring, involving the governance of entities and involving control systems to ensure that commitments made are monitored, and lastly, taking into account the risks related to biodiversity loss in their commitments and operational implementation at the level of business lines.

With regard to the recommendations specific to the carbon policies of French financial institutions, concerning the measurement of exposures and the identification of the scope of operations, the ACPR and the AMF recommend continuing the work underway to improve the measurement of institutions' exposures, in particular by establishing transparent and verifiable methods. According to the two authorities, the role of the federations in this process is essential, not only for a coordinated and harmonised approach, but also for the dissemination of best practices. The two authorities also recommend that the operations, financial instruments and other banking or financial services concerned by the institutions' coal policies be displayed in a more visible and transparent manner, and that the databases used be systematically specified. Also on 18 December 2020, the AMF published a report on TCFD climate reporting in the financial sector by studying the reporting practices of ten French players, based on an in-depth analysis of published TCFD reports and interviews. This study highlights the main difficulties encountered and presents several avenues of work to support players wishing to engage in this voluntary transparency approach. The AMF report stresses that this is a demanding exercise, but one that is unanimously emphasised as useful. In general, the French framework provides a solid basis for governance and risk management through regulatory and prudential requirements supplemented by market work. It also prescribes climate-related disclosure requirements through the extra-financial performance statements of Article 173, although meeting all of the TCFD's recommendations, which also aim to change practices in depth, remains a challenge for financial institutions. While the publication of a TCFD report helps to structure the climate approach of companies and to raise awareness internally, the integration of climate factors into the company's overall strategy remains a challenge for signatory institutions and needs to be demonstrated outside of the setting of commercial objectives for "green" products.

The reporting exercise makes it possible to expose the issues to be addressed, the difficulties encountered and to initiate a process of continuous progress for the most advanced players. Nevertheless, the TCFD's objective is to publish information that is useful for decision-making and for understanding the financial risk of climate change at the level of a financial institution. The AMF stresses that this objective has not yet been achieved and that further efforts are needed, both at the individual level and through market initiatives. The AMF's analysis of reporting shows the large number of climate risk analysis and management tools that financial institutions are trying out. Nevertheless, these tools are still rarely integrated into the risk management of the various entities with, for example, alert thresholds or limits that could have an impact on asset allocation or financing decisions, even if the institutions indicate that they want to move in this direction. As in other extra-financial areas, the TCFD reports analysed still use a wide variety of metrics. Although the relative novelty of the exercise has not yet led to harmonisation, it has nevertheless encouraged innovation. Transparency about the approaches taken and their limitations is a key factor in advancing the maturity of practices. More recently, on 10 May 2021, the AMF published a study providing an initial overview of the fees and performance of funds marketed in France that incorporate an extra-financial approach between 2012 and 2018, against a backdrop of significant development of sustainable finance and fund ranges that include environmental, social and governance (ESG) criteria. A database of 28,480 fund units marketed in France was analysed to distinguish those that signalled an extra-financial approach either by a mention in their commercial name according to a list of keywords identifying 1,340 fund units, or by obtaining a French label, i.e. 1,108 fund units. This data allowed for an analysis based solely on the rate of fees on assets under management (TFE), i.e. an aggregation of current fees and performance fees. The findings of this study are therefore based on a partial view of the fees charged to investors. The analysis shows that shares in funds that take extra-financial criteria into account tend to be less expensive than their equivalents without an extra-financial approach. A fund unit claiming the integration of extra-financial criteria in its name and holding a label would have been on average 0.17 percentage points cheaper than an equivalent standard fund unit over the analysis period. A robustness test, conducted on the year 2019 only, seems to confirm the validity of the results. For the total sample in 2019, the TER of a fund without any extra-financial reference would be 0.10 percentage points higher than that of a fund claiming to take into account extra-financial criteria and holding a label. Several hypotheses could explain this lower cost (proactive policy of management companies, lower management fees corresponding to a reduced scope of assets, etc.). These results must be considered with caution: the period studied corresponds to a phase of structuring of the extra-financial market which may not be representative of the current situation. In order to combat greenwashing and to help investors identify green funds more easily, a number of labels have been introduced. The AMF published a doctrine in 2020 that imposes minimum standards for products that communicate on the inclusion of extra-financial criteria. The AMF also believes that it is vital to promote transparency on fees in order to boost investor confidence and thus enable more savings to be mobilised to finance the economy.