How to Read AMF and Euronext Filings

Section 1Why the French regime reads differently

If you want to know what a US Bitcoin treasury company owes its shareholders, you read EDGAR. The 8-K lands, the 10-Q reconciles it, and the search index is free, complete, and machine readable.

France does not work that way, and Euronext Growth Paris works even less that way. There is no EDGAR. There is a company website, a regulator's database, an exchange news feed, and a wire service. The authoritative copy is not always the one a search engine hands you first. The documents are written and published in French, and an English translation, where one exists, is a courtesy rather than an obligation.

For anyone reconciling a capital structure that is the difference between a claims figure that traces to a filing and a claims figure that traces to a press aggregator's paraphrase of a translation. The two look identical on a page. Only one of them survives a check.

Section 2The document family

Each term below is written to stand alone. If you arrived looking for one of them, read that entry and stop.

Communiqué de presse

A communiqué de presse is a press release issued by a French listed company. English language coverage calls it a press release, but in this regime it carries a specific weight: for a Euronext Growth issuer the communiqué is frequently the only place a given capital action is disclosed, which makes it the disclosure of record rather than a summary of something filed elsewhere.

Companies of this type publish in parallel French and English versions, and the same release surfaces on the company investor page, on a wire service, and on the Euronext company news feed.

Authoritative for: BTC purchases, conversions, capital increases, warrant exercises, and the use of a delegation. For a Growth issuer this is the primary event source.

Not authoritative for: anything audited. A communiqué is management's account, published the same day. The half-year and annual reports are where an auditor becomes involved, and where a communiqué gets corrected. Section 7 shows that happening.

Rapport financier semestriel

The rapport financier semestriel is the half-year financial report covering January to June, published in the autumn. It carries an activity report, condensed consolidated statements, the notes to those statements, and a statutory auditors' report.

For a treasury company this is the second most valuable document in the family, because it is the first place instrument terms, accounting classification and the going concern picture appear together and in one another's context.

Rapport financier annuel

The rapport financier annuel is the annual financial report for the fiscal year ended December 31. It carries the audited accounts, the management report, the governance report, and the debt note covered in Section 5.

This is the most valuable single document in the family. The denomination of the convertible obligation is answered here and nowhere else with the same authority. Capital raising capacity is described here too, in narrative rather than in a table, and the communiqués carry the same delegation references, so the annual report is the better source for capacity but not the only one.

Prospectus, and supplément au prospectus

A prospectus is the offer document required when securities are offered to the public or admitted to trading above the applicable thresholds under the EU Prospectus Regulation. A supplément amends it when a significant new factor arises before the offer closes.

On Growth you will often find a raise completed with no prospectus, but do not assume the venue is the reason. Read the exemption the release cites: an offer restricted to qualified investors is exempt under the Prospectus Regulation whatever the venue, and a Growth issuer's release will name the article it relies on.

Practical consequence: if you go looking for a prospectus to source a convertible's terms on a Growth name, you will usually not find one. The terms live in the communiqué first and in the notes to the accounts afterwards. That is Section 5.

Document d'enregistrement universel

A document d'enregistrement universel, universal registration document or URD, is the annual shelf document a French issuer may file to consolidate its company description, risk factors, governance and financial statements into one reference filing, simplifying later offerings.

Growth issuers generally do not file a universal registration document, and this one does not. Treat the absence as a working assumption to confirm per issuer rather than as a rule. Where a URD does exist and carries regulated information, the issuer submits it through ONDE, the AMF's submission extranet.

The portals

A portal that will not resolve is not a reason to substitute a secondary source. It is a reason to cite the company published or exchange published copy you did read, and to say which one it was.

Section 3Euronext Growth is not the regulated market

This distinction governs everything else, so it gets its own section. Euronext Growth Paris is a multilateral trading facility, not a regulated market. Four things follow.

Periodic disclosure is lighter. The Transparency Directive sets the minimum periodic obligations for issuers on a regulated market. Growth issuers sit outside that baseline and follow the exchange's own rulebook instead, in practice an annual and a half-year report rather than a fuller quarterly cadence.

The supervisor is different, and this is the part that gets misread. The AMF checks that periodic reports are duly published by companies listed on the regulated market, and publishes a list of late filers where its prompting fails. For Euronext Growth, the exchange itself checks that registered companies have published their periodic information on their own websites, and publishes its own late list.

Ongoing disclosure of inside information is the same. Market abuse rules apply to Growth issuers as they do on the regulated market, and price sensitive information must be disclosed promptly either way. This is why the communiqué stream stays dense even though the periodic stream is thin.

AMF doctrine still appears. A Growth issuer citing an AMF internal control framework or periodic information guide in its own risk factors is following good practice, not discharging a Transparency Directive duty. Read the citation as a signal about the issuer, not as evidence about the venue.

The generalisation note

This page is written from Paris. Most of the structural logic, Growth against regulated market, the communiqué as the event of record, the notes to the accounts as the place instrument terms live, travels across Euronext venues, because Euronext Growth operates in Paris, Brussels, Amsterdam, Dublin, Lisbon, Milan and Oslo under a shared rulebook.

The regulator does not travel. A Growth issuer in Brussels answers to the FSMA, in Amsterdam to the AFM. Filing portals, submission systems, language requirements and doctrine documents are national. The document family crosses a border. The filing path does not.

Section 4Where the holdings updates live, and what is inside one

A French treasury issuer discloses Bitcoin acquisitions by communiqué, usually in the same week, in parallel language versions. The pattern is stable enough to read as a template with five parts.

Two traps live in part five.

First, the diluted definition moves between releases, and can differ between two tables inside one release. Read the basis beside each figure before comparing any two. One release may enumerate outstanding shares, shares from conversion of all issued convertibles, granted but unvested free shares, and a further tranche of free shares not yet granted but included conservatively. The next release may draw the line somewhere else. Different releases, different components. A diluted figure from one release cannot be compared to a diluted figure from another without reading both footnotes.

Second, and heavier for claims work: an operational coin tranche can be segregated and excluded from the company's own metrics. Where an issuer holds coins allocated to operating needs and states that they sit outside the reserve and outside the published metrics, the headline holdings figure in that release has already taken a position on a question the framework has to answer for itself. Total BTC is a numerator input. Whether the operational tranche belongs in it is a decision that has to be made and stated, and the release has made the opposite choice from at least one of the two available answers.

Section 5The convertible layer, and where the terms live

OCA, obligations convertibles en actions, are convertible bonds. On a French treasury name this is the instrument class carrying the senior claims, and it is where the reading gets hard.

The communiqué announces the instrument. The notes to the accounts are where the terms can be read as a set, alongside the accounting classification and the conversion history. The worked pattern: communiqué for the event, notes for the structure, annual report debt note for the obligation.

Subscription currency and redemption denomination are two questions

This is the single most useful thing on this page, and it is a distinction rather than a number.

A half-year note may state that one series of bonds was subscribed for in euros and another series subscribed for in bitcoin. That sentence is real, it is citable, and it is load bearing for what it says. It describes how the bonds were paid for at issuance. It says nothing about what the issuer owes at redemption.

The tempting reading is that this is a denomination split: one series fiat fixed, the other coin denominated, two claim behaviours in one stack. A claims model built on that reading can be wrong while citing a real sentence from a real filing, which is the failure mode worth naming, because nothing about the citation looks weak.

Redemption denomination is answered separately, in the annual report's debt note, where the obligation may be expressed as a single coin quantity covering the entire stack. That is the issuer stating in audited accounts what the obligation is denominated in, and it is the load bearing source for any claims work on the name.

The gates vocabulary

These instruments carry conditional language that recurs across issuances. Learning the shapes is worth more than learning any one instrument.

The conversion gate. Conversion at any time during the conversion period, provided that a trailing volume weighted average share price reaches a stated multiple of the conversion price. That is a price contingent conversion right, not a hard maturity conversion and not holder optional at will. The claim's persistence is a function of where the stock trades, which is exactly the contingency a static claims figure erases.

The tranche gate. Tranche two of a series conditional on tranche one holders exercising a subscription option inside a stated window. An announced two tranche programme is not an announced claim. Tranche two is an option on a claim, and it expires. Counting announced nominal as outstanding senior claims is a category error.

The adjustment gate. Holders benefit from legal adjustment measures, anti dilution protection triggered by later capital events, which issue shares to holders outside conversion. Adjustment measures are a claim growth mechanism attaching to the instrument, they are contractual, and they are documented in the instrument rather than announced as a policy.

The corporate action gate. Conversion rights can be suspended by corporate action, for example across the window of a share consolidation. A claim that cannot convert for several weeks is not a different claim, but a model assuming continuous convertibility across that window will misdate conversions.

Read the table, not the prose

Vocabulary quick reference

Section 6The capacity layer: délégations de compétence

A délégation de compétence is a shareholder authorisation granting the board power to carry out capital increases within a stated ceiling and period. Nothing on the funding side happens without one, and every communiqué announcing an issuance names the meeting and resolution it draws on.

Three properties of these authorisations decide how you read a ceiling.

They replace rather than stack. A later meeting's delegations can expressly supersede an earlier meeting's. Summing announced ceilings across meetings double counts, and the double count is large enough to change a conclusion.

Equity capacity and debt capacity are separate ceilings. An authorisation for capital increases and an authorisation for the issuance of credit instruments are two numbers on two lines. Conflating them produces a capacity figure that does not exist.

They expire. A délégation carries a statutory maximum validity running from the authorising meeting. A ceiling announced at one annual meeting is not standing capacity three years later. Read the validity period off the Code de commerce article the resolution cites rather than assuming a term.

Section 7The euro layer: state your basis, or do not state a number

A euro reporting company holding a dollar quoted asset creates a conversion problem in every direction. A good filing handles it explicitly, which makes it a good teacher.

The stated basis. A well drafted note gives the coin exchange rate used for the period, names the source, and ties it to a specific reporting date. Every euro denominated coin figure in those accounts sits on that basis.

Then the trap. The same document's summary section can carry a holdings figure as of the date of the document rather than the balance sheet date, and an average acquisition cost per coin rather than a market rate on any date at all. Four quantities, one document, on three different bases:

Multiply the later coin count by the earlier closing rate and you have produced a number that corresponds to nothing. Multiply the earlier coin count by the blended cost and you have a period end count at a historical cost. Both are wrong, both look plausible, and both land within an order of magnitude of a right answer, which is what makes them expensive.

The same document can do this with share capital. A cover page stating share capital at signing and a note stating share capital at the balance sheet date are both correct and months apart. Cite the cover for a current capital claim and you have misdated it.

And where a euro figure derives from a coin price assumption rather than a coin price observation, say so. Issuers do: a filing that restates a press release's nominal and names the coin price assumption behind the original figure is showing you both the correction and its cause in one sentence.

Section 8The aggregator pattern, and the order of authority

Thin English language coverage of a Euronext Growth name has a specific failure signature. It is not random noise. It is systematic, directional, and repeatable enough to predict.

None of these are careless errors. They are what a competent English language process produces when it meets a French language primary source, a renamed issuer, a renamed foreign subsidiary, a conditional instrument and a share consolidation. Every hop is individually reasonable, and the result is still not usable.

The order of authority

Rule five is the one that costs something to keep. A pending marker is visibly incomplete, and a substituted figure is invisibly wrong. Only one of those can be found later by someone checking.