#
France's crypto licensing regime is anchored in Regulation (EU) 2023/1114 (MiCA), administered domestically by the AMF against the backdrop of the 2019 PACTE Law's original PSAN/DASP registration regime. The AMF requires CASP authorisation under MiCA Articles 59/60 before any entity may lawfully provide crypto-asset services in France or across the EU; this core authorisation-requirement claim was re-anchored this cycle from a T4 news source to ESMA's own T1 MiCA overview page following a Challenger flag, with confidence correspondingly adjusted from Confirmed to Probable under the two-anchor Confirmed standard. The EU-wide MiCA Article 143 grandfathering period, which had allowed pre-existing PSAN-registered entities to continue operating without a full CASP licence, expired on 1 July 2026; unauthorised providers are now required to wind down EU client-facing activity, per ESMA's own statement on the end of transitional periods, corroborated to Confirmed. The pre-MiCA PACTE Law national registration regime for digital asset service providers remains the historical foundation of this framework, confirmed via a Bank for International Settlements republication of a Banque de France statement. Concrete licensing activity continues under the new regime: SwissBorg's French entity, BlockNodes SAS, obtained full MiCA CASP authorisation from the AMF covering custody, execution, transfer/placing, portfolio management and advice services, with the grant date corrected this cycle from 12 March 2026 (press release) to 5 March 2026, matching the AMF's own white-list register entry.
The most consequential structural development this cycle is the 1 July 2026 expiry of the EU-wide MiCA Article 143 grandfathering period. That transitional mechanism had permitted entities already registered as PSANs under the pre-MiCA national regime to continue operating without a full CASP licence for a defined window; with its expiry, ESMA has stated publicly that any provider that has not obtained CASP authorisation must wind down its EU client-facing activity in an orderly manner. This effectively ends nearly two years during which France's national PSAN registration and the EU's MiCA CASP authorisation coexisted as parallel, overlapping legal bases, leaving MiCA CASP status as the sole operative licensing pathway going forward.
The PACTE Law's 2019 registration regime remains historically significant as the precursor framework, confirmed via a Bank for International Settlements republication of a Banque de France statement, and continues to shape the domestic administrative apparatus even as its substantive licensing function has been superseded by MiCA.
Concrete licensing activity under the new regime continues to be documented. SwissBorg's French entity, BlockNodes SAS, obtained full MiCA CASP authorisation from the AMF, spanning custody, execution, transfer and placing, portfolio management and advisory services. This cycle's review corrected the recorded grant date: the AMF's own white-list register places the authorisation on 5 March 2026, seven days earlier than the date carried in the original press-release-sourced claim, and the claim has been re-anchored to that primary register entry accordingly.
Outlook
With the grandfathering period now closed, the near-term monitoring priority shifts to enforcement: whether ESMA and the AMF follow through visibly on winding down unauthorised providers' EU client-facing activity, and whether additional CASP authorisation grants (of the kind evidenced by BlockNodes SAS) continue at pace as remaining incumbents complete the transition. A residual open question concerns the precise French national-level grandfathering duration for FR-specific PSAN incumbents, distinct from the EU-wide 1 July 2026 backstop, which was not directly extracted from ESMA's grandfathering-periods list this cycle and remains a documented gap for the next research pass.
Crypto Licensing
France's crypto-asset licensing regime completed its transition to MiCA during this reporting window. The national PSAN (Prestataire de Services sur Actifs Numériques) registration regime was repealed with effect from 1 July 2026, and all PSAN-only registrants — providers that had not separately obtained MiCA CASP authorisation — were automatically deregistered on 2 July 2026. This was a lapse of right under the transitional timetable rather than a discretionary enforcement decision by the AMF, and it closes the national registration bridge that had allowed providers to operate under PSAN pending full MiCA authorisation.
From 1 July 2026 onward, crypto-asset services may be provided in France only through one of two routes: MiCA CASP authorisation granted by the AMF, or the Article 60 notification route available to firms already authorised in another capacity under the regulation. New entrants to the French market cannot use the now-closed PSAN transitional bridge; they must proceed directly to full CASP authorisation or qualify for the Article 60 notification route. The AMF has stated it is accepting CASP authorisation applications, consistent with its role as the national competent authority under the regulation.
The exposure for operating outside this perimeter is criminal rather than purely administrative: providing crypto-asset services in France after 1 July 2026 without a granted MiCA CASP authorisation exposes the provider to up to two years' imprisonment and a €30,000 fine. This penalty structure applies to continued unauthorised provision following the PSAN sunset, not merely to new unauthorised entry, which raises the stakes for any provider whose PSAN registration lapsed without a completed or pending CASP application.
Outlook
The regime is now settled onto a single MiCA-only gate, and the near-term question is less about the law itself and more about population tracking: the AMF's CASP-authorised count was last confirmed at 37 as of 25 August 2026, and that figure has not been reconfirmed since the PSAN sunset took effect. A reconfirmed count would show how many former PSAN registrants completed the transition to full authorisation versus how many were deregistered without replacement authorisation, which bears directly on how much of the pre-MiCA registered population remains active in the French market.
5 earlier distinct update(s)
Crypto Licensing
France's national transitional bridge from its pre-existing PSAN (Prestataire de Services sur Actifs Numériques) registration regime to full authorisation under the EU's Markets in Crypto-Assets Regulation came to an end on 1 July 2026. This date was fixed under domestic instruments, Ordonnance n°2024-936 and Décret n°2025-169, and operated as France's own national transitional end-date, distinct from and earlier than the outer EU-wide transitional limit available under MiCA Article 143(3). For PSAN-registered entities operating in France specifically, the French date governed rather than the later EU backstop, meaning the French market closed its transition window on a tighter timeline than MiCA's maximum period would otherwise have permitted. This finding is confirmed at Tier 3 sourcing for the national-date mechanics specifically, though the underlying transitional architecture itself is corroborated by the AMF's own Tier 1 published material.
The legal consequence of the cutover is significant and confirmed at Tier 1 sourcing: any provider exercising crypto-asset services in France without the requisite Payment Services and Crypto-Assets authorisation, after the 1 July 2026 transitional end-date, now commits a criminal offence under Code monétaire et financier articles L.54-10-4 and L.572-23, carrying exposure to two years' imprisonment and a thirty-thousand-euro fine. This is a materially different enforcement posture from the pre-cutover period, when PSAN registration alone, a lighter-touch national regime, was sufficient to operate lawfully. The criminalisation of unauthorised operation past the cutover date represents the sharp edge of France's PSAN-to-MiCA migration: a provider that failed to secure PSCA authorisation in time does not simply lose a registration status, it crosses into criminal unlawfulness.
A second, distinct penalty tier attaches to registration-integrity failures short of outright unauthorised operation. Secondary legal commentary, held at probable rather than confirmed confidence pending retrieval of the underlying statutory text, describes a separate offence for failing to notify the AMF of changes affecting a PSAN or PSCA registration, or for transmitting inaccurate information to the regulator, introduced via the same Ordonnance n°2024-936. This carries lower exposure, one year's imprisonment and a fifteen-thousand-euro fine for natural persons, rising to seventy-five thousand euros for legal persons, consistent with a tiered enforcement design that reserves the heaviest criminal exposure for entirely unauthorised operation while still imposing meaningful criminal risk on registered or authorised firms that fail to keep their regulatory filings current and accurate.
The AMF's own published figures, dated 19 January 2026 and therefore a snapshot taken before the 1 July 2026 cliff-edge itself, recorded ninety registrations and seventy-nine authorisations under the evolving regime. The gap between these two figures, eleven entities registered but not yet authorised at that snapshot date, indicates a meaningful population of PSAN-era operators still mid-transition as the hard deadline approached. What happened to that residual population at the cutover itself, whether they completed authorisation in the intervening months, exited the French market, or continued operating and now face the criminal exposure described above, has not been established this cycle; no AMF or ACPR enforcement or market-exit data addressing the post-cutover period was retrieved.
Taken together, the architecture that has now fully crystallised in France is a binary one: PSCA authorisation under MiCA, implemented nationally through Ordonnance n°2024-936 and Décret n°2025-169, is now the sole lawful basis for crypto-asset service provision in France, with criminal liability attaching sharply at the point a provider operates without it. This is a settled, confirmed architectural fact rather than a currently-moving rule; the transition itself is complete, and the national transitional date that once distinguished France from the EU-wide backstop is now a historical fact relevant chiefly to understanding why the French cutover preceded dates that may have applied in other Member States.
Outlook
The principal open question is enforcement follow-through against the residual gap identified in the AMF's own pre-cutover figures: whether any of the eleven entities registered but not yet authorised as of 19 January 2026 have since faced criminal exposure under articles L.54-10-4 and L.572-23, secured late authorisation, or exited the French market. No enforcement action, market-exit data, or updated AMF registration count addressing the post-1-July-2026 period was retrieved this cycle, and closing this gap would be the natural focus of subsequent research. A secondary item worth tracking is whether the AMF or courts have yet applied the separate, lower-tier notification-failure offence described in secondary commentary, which would help confirm that finding at a higher confidence level than the current single-source, Tier 3 sourcing permits.
Crypto Licensing
France's national PSAN registration regime ceased to authorise new entrants when the MiCA transitional window closed on 1 July 2026. The AMF's own confirmation states that digital asset service providers engaged in crypto-asset service provision before MiCA's entry into force had until 1 July 2026 to obtain PSCA authorisation under MiCA; providers who did not secure this authorisation lost their basis to continue operating in France. Crypto-asset service providers must now hold MiCA CASP authorisation from the AMF, with ACPR co-approval required for certain payment- or e-money-adjacent categories, since the national PSAN route no longer authorises new entrants.
The practical consequences of missing the deadline are material. Secondary trade-press reporting describes the criminal exposure for operating as a crypto-asset service provider in France without MiCA authorisation after 1 July 2026 as up to two years imprisonment and a fine of euro30,000. This is a materially harder line than a purely administrative or civil consequence, and it signals that France treats unauthorised crypto-asset service provision post-deadline as a criminal matter, not merely a licensing gap to be remedied.
The transition itself was staged rather than a single cliff-edge event. Non-MiCA-ready PSANs were required, according to secondary law-firm reporting, to implement an orderly wind-down plan and to cease all but strictly necessary settlement operations from 30 March 2026 at the latest — a full three months ahead of the final 1 July 2026 cutoff. This gave the market visibility into which providers were exiting well before the headline deadline arrived, and it suggests the AMF sequenced the closure of the national route deliberately rather than allowing a disorderly last-minute exit wave.
Taken together, these developments mark a structural tightening of France's crypto-licensing perimeter: the national registration route that had provided an alternative to full MiCA authorisation is now closed to new entrants, and the consequence of operating without the harmonised EU authorisation is criminal rather than merely administrative. This is consistent with the EU-wide MiCA harmonisation architecture rather than an FR-specific innovation, but France's implementation — the wind-down staging and the criminal-penalty framing — reflects a firm domestic enforcement posture layered on top of the EU baseline.
Outlook
The open question for the coming cycles is enforcement follow-through: whether the AMF names and sanctions any provider that continued crypto-asset service provision in France without authorisation after the 1 July 2026 deadline. No such confirmed T1 enforcement action was identified this cycle, despite secondary reporting describing at least one major platform as having ceased onboarding of French clients around the same date. Confirmation or absence of a named enforcement action in the next cycle will be the clearest signal of how actively the AMF intends to police the post-deadline perimeter it has now established.
Crypto Licensing
France's crypto-asset licensing regime reached a structural turning point this cycle with the expiry of the PSAN-to-MiCA CASP transitional period on 1 July 2026. From that date, MiCA authorisation, or an eligible Article 60 notification, is required to provide crypto-asset services in France; this is a confirmed finding sourced directly from AMF's own reminder communication to digital-asset service providers, the highest-confidence and highest-tier evidence available in this module this cycle. The practical effect is the elimination of the parallel national PSAN registration track that had allowed legacy-registered entities to continue operating during the transition window. Supervisory responsibility is divided between two French authorities: the AMF acts as the principal competent authority for CASP authorisation, while the ACPR supervises issuers of asset-referenced tokens and e-money tokens and co-assesses any CASP offering EMT-related or payment-institution-adjacent services. This allocation is described at probable confidence from a T3 practitioner guide rather than from a primary AMF or ACPR doctrine document, and should be read with that caveat, though it is consistent with the standard MiCA supervisory model applied across other EU member states.
The consequence of operating without the required authorisation is not merely administrative. Providing crypto-asset services in France without MiCA authorisation now exposes a provider to criminal sanction: up to two years' imprisonment and a 30,000 euro fine under the Code monetaire et financier, a probable-confidence, T3-sourced finding. This criminal sanction exposure, combined with the hard 1 July 2026 cutoff, gives the transition closure real enforcement weight rather than functioning as a purely declaratory milestone. Two gaps remain open in the evidence base this cycle: the exact numeric KYC engagement threshold applicable to CASPs under the post-transition regime has not been independently confirmed against a T1 ACPR or AMF source, and the module has not yet surfaced any concrete enforcement action against former-PSAN entities that failed to transition, which would be the clearest test of how firmly the new authorisation requirement is being applied in practice.
Outlook
The key development to watch in the coming cycle is whether AMF and ACPR take visible enforcement action against any former-PSAN entities that did not secure MiCA authorisation or an eligible Article 60 notification ahead of the 1 July 2026 deadline. Confirmation of the precise KYC engagement threshold against a primary regulatory source would also resolve a standing evidence gap and sharpen the operational-compliance picture for CASPs operating under the new regime.
Crypto Licensing
France's crypto-asset licensing framework underwent a definitive structural transition this cycle. Effective 1 July 2026, the Autorité des Marchés Financiers confirmed that crypto-asset service providers in France must hold MiCA CASP authorisation, granted by the AMF with the ACPR involved for certain prudential and AML-relevant categories; the PACTE-law PSAN transitional registration, in place since 2019, no longer permits new activity beyond that date. This is a confirmed, Tier 1 finding sourced directly to the AMF, representing the closure of what had been continental Europe's most mature pre-MiCA national crypto-asset registration framework.
The transition carried a defined wind-down mechanism for firms unable to secure authorisation in time: digital-asset service providers were expected to implement an orderly-cessation plan, limited to strictly necessary wind-down operations, by 30 March 2026 at the latest, a measure the AMF frames explicitly as protecting crypto-asset holders during the transition period. This is also confirmed at Tier 1. Separately, the framework permits an alternative route for certain eligible financial entities: the Article 60 MiCA notification mechanism may substitute for full CASP authorisation, subject to the AMF deeming the notification complete. This finding carries Probable confidence, reflecting its Tier 3 sourcing rather than direct AMF confirmation.
Taken together, these developments mean the French crypto-licensing perimeter is now defined exclusively by the MiCA CASP authorisation track and the narrower Article 60 notification alternative; the PSAN framework that formerly ran in parallel with, and preceded, MiCA no longer offers an independent basis for lawful crypto-asset-service provision in France.
Outlook
The key development to watch is AMF enforcement posture toward any residual unauthorised digital-asset service providers who neither secured CASP authorisation nor completed an orderly wind-down by the applicable deadlines, since this is where the practical consequences of the regime closure will be tested. Further AMF or ACPR guidance clarifying the scope and eligibility criteria for the Article 60 notification alternative would also be a material development to track, given its current Probable-confidence, Tier 3-only evidentiary basis.
Crypto Licensing
France's crypto-licensing framework completed its structural transition this cycle. From 1 July 2026, only MiCA-authorised crypto-asset service providers, or entities notified under Article 60, may provide crypto-asset services in France; legacy PSAN/DASP registration under the prior national regime no longer suffices. This cutover has a two-track history: new crypto-service entrants to the French market have required full MiCA CASP authorisation since 30 December 2024, with no access to any transitional window at all, while DASPs already registered under national law prior to the MiCA CASP provisions were permitted a transitional period running only until 1 July 2026, under Article 143 of MiCA and Article 8-III of the DDADUE Law.
The practical effect this cycle is that the transitional cohort has now reached its hard deadline, and the AMF is actively enforcing it. The framework itself, MiCA Regulation (EU) 2023/1114 as implemented domestically through Ordinance 2024-936 and Decree 2025-169, is settled and supervised by the AMF; what remains unresolved is the compliance status of the legacy operator population that relied on the transitional window. This is reflected in an amber traffic-light rating: the legal architecture is stable and durable, but a materially sized cohort of previously-registered operators faces active non-compliance and wind-down risk.
No new French entrant this cycle benefits from any relief, and the regulatory bar for market access in France is now uniformly the full MiCA CASP authorisation regardless of an operator's registration history, for anyone seeking to provide crypto-asset services after the cutover date.
Outlook
The critical marker for the next cycle is the disposition of the legacy PSAN/DASP cohort that had not secured MiCA authorisation by 1 July 2026: continued AMF registration withdrawals, confirmed successful authorisations, or transitions into orderly wind-down. The scale of this cohort is analytically significant as a concentrated supervisory event rather than an isolated licensing matter.
Sources and findings (4)
- T1 · ESMAAMF — CASP authorisation under MiCA Articles 59/60 before lawfully providing crypto-asset services in France and the EUretrieved M5bindingin forceupdated
- T1 · ESMAMiCA Article 143 grandfathering regime — EU-wide transitional period allowing pre-existing PSAN-registered entities to operate without a MiCA CASP licence ended 1 July 2026; unauthorised providers must wind down EU client-facing activityretrieved M5bindingin force
- T1 · Bank for International Settlements (republishing Banque de France speech)France (PACTE Law 2019) — a dedicated national registration/licensing regime for digital asset service providers (PSAN/DASP)retrieved M4bindingin force
- T1 · Autorité des Marchés Financiers (AMF)SwissBorg / BlockNodes SAS — full MiCA CASP authorisation from the AMF, covering custody, execution, transfer/placing, portfolio management and advice servicesretrieved M2non-bindingupdated