The AMF's SPOT 2025 campaign reveals that call recording compliance is failing as companies struggle to ensure systems work properly, even as voice orders decline.
Recording systems not always reliable
The SPOT 2025 control campaign conducted by the AMF shows that simply recording calls is not enough for compliance. Companies often fail to ensure that their recording systems are actually working properly, even if they know how to set them up.Decline in voice order use
The AMF found that fewer investment management companies are using voice orders over the phone. In the summer of 2025, only 19% of surveyed companies used this method, signaling a shift in how orders are executed.Risk remains high despite lower usage
The AMF warns that the risk associated with telephone-based orders doesn't decrease with lower usage. In fact, it can become more complex to manage, especially as the telephone is no longer the main channel for operations.Smartphones complicate compliance
The smartphone has changed how companies handle communication. In five inspected companies, mobile call recordings relied on an app connected to the company's system. However, none checked whether employees actually used the app instead of their phone's native features.Modern telephony is distributed
Today's telephony systems are spread across smartphones, remote work, and various applications. Compliance cannot rely only on initial setup and employee procedures. It must be continuously observable and detectable.Missing recordings raise concerns
The SPOT campaign found that some companies couldn’t provide requested recordings. In one instance, orders were placed from an unrecorded phone, and the files had to be retrieved from the broker, raising questions about the effectiveness of recording systems.Retention rules need verification
The AMF suggests a standard five-year retention period for recordings, with the option to extend to seven years. However, this rule only matters if companies can confirm that it is being followed, including ensuring files are not deleted prematurely or are easily accessible.Access to recordings must be secure
The SPOT control also found risks when accessing recordings indirectly, such as when a team handles the files. A mature system must ensure that access is secure, traceable, and immediate. Otherwise, the recordings are of limited value.Internal controls fail to detect issues
Despite having formalized controls, some companies in the sample failed to detect problems like recording failures or the use of unrecorded phones. The AMF recommends regular and risk-based checks, such as listening to a sample of voice orders quarterly.
