France

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and continues to shape the domestic administrative apparatus even as its substantive licensing function has been superseded by MiCA.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.

The PACTE-era AMF ICO visa regime continues to restrict eligible public token offerings to utility tokens that do not qualify as financial instruments. This claim's materiality sits below the threshold that triggers the chase protocol for stronger sourcing, and it currently rests on a single trade-press anchor pending a stronger primary source; it is retained as Confirmed on the strength of that single anchor but flagged here as an area where a stronger citation would be useful.

At the classification boundary between MiCA-scoped crypto-assets and traditional securities law, ESMA directs national competent authorities, including the AMF, to apply a substance-over-form three-criteria test in determining when a given crypto-asset in fact qualifies as a MiFID II transferable security and therefore falls outside MiCA's scope entirely. This guideline, anchored to ESMA's own published text, gives the classification regime a degree of built-in flexibility to catch instruments that superficially resemble crypto-assets but function economically as securities.

Non-fungible tokens receive express treatment under the underlying statute: MiCA excludes crypto-assets that are unique and non-fungible with other crypto-assets from its scope entirely, per Article 2 of the regulation, an exclusion confirmed directly against the EUR-Lex statutory text.

Outlook

The classification taxonomy itself appears stable and unlikely to see near-term legislative change; the more active monitoring surface is likely to be case-by-case application, particularly at the security-token boundary where ESMA's substance-over-form test will continue to generate individual determinations as new token structures come to market, and in the ICO visa space where a stronger primary source for the utility-token eligibility rule would improve confidence beyond the current trade-press anchor.

The more consequential finding this cycle comes directly from ESMA and EBA's own joint Article 142 MiCA report: self-custodial wallets and DeFi lending or staking protocols are not generally subject to MiCA authorisation or AML/CFT requirements where no identifiable intermediary exists. This is a negative finding in the sense that it documents an absence of binding regulation rather than a rule, but it is significant precisely because it comes from the regulators' own analysis rather than external commentary, and it applies across the EU rather than being a France-specific gap. Readers should not interpret this as evidence of imminent French unilateral action; it describes the current EU-wide perimeter as the regulators themselves understand it.

Separately, a joint strategic group bringing together the Banque de France, the French Treasury and the AMF has been formed to focus on distributed ledger technology and tokenisation innovation. This is a non-normative institutional development -- it establishes a forum for coordination, not a binding rule -- and should be read as a signal of official attention to the space rather than a regulatory commitment.

Outlook

The central open question for this module is whether the EU-level regulatory gap around non-custodial DeFi and self-hosted wallets narrows through a future legislative vehicle, or whether the current Article 142 joint-report position (no binding perimeter absent an identifiable intermediary) persists as the settled EU stance for the foreseeable future. The newly formed Banque de France/Treasury/AMF DLT strategic group is worth tracking for any binding output, though none has emerged as of this cycle.

The same sourcing pattern and correction apply to two related claims. SG-FORGE's EURCV and USDCV tokens are represented as backed by fully segregated fiat reserves held at regulated custodian banks -- Société Générale for the euro leg, BNY Mellon for the dollar leg -- consistent with MiCA's EMT reserve requirements; and EURCV holders within the EEA are represented as entitled to redeem their tokens at par value directly from SG-FORGE or through approved partners, in line with MiCA Article 49's redemption-right requirements. Both claims rested solely on a single price-tracker page rather than a primary source, and both have been downgraded to Probable this cycle on the same sourcing-normalisation basis as the issuance-authorisation claim.

A distinct, non-technical development concerns policy advocacy rather than binding rulemaking: Banque de France leadership has publicly advocated strengthening MiCA to restrict the use of non-bank and non-EU stablecoins for everyday payments, citing counterparty-risk concerns. This is explicitly a proposal-stage position with no enacted instrument behind it, and should be read as a signal of official French policy preference rather than a rule currently in force.

Outlook

The near-term priority for confidence-building in this module is sourcing: obtaining primary ACPR or EBA citations for the issuance-authorisation, reserve-backing and redemption-right claims would allow these materiality-4/5 binding claims to be restored to Confirmed status. Separately, the Banque de France's payments-restriction advocacy is worth tracking for any sign of translation into a concrete legislative proposal, particularly given its cross-border payments relevance.

Licensed French digital-asset custodians are also required to maintain a claims and complaint-handling procedure, under which clients are compensated where the custodian is unable to restore control of client assets. This claim, too, was found to rest solely on a single trade-press source and has been downgraded to Probable this cycle under the same two-anchor Confirmed standard.

On the disclosure side, ESMA directs both EU and French consumers to verify a CASP's authorisation status directly in the ESMA Interim MiCA Register before investing, since MiCA's investor protections attach only to the specific authorised legal entity providing the service, not to an affiliated brand or group more broadly. This directive is anchored to ESMA's own public statement and retains Confirmed-tier confidence.

One area of the consumer-protection landscape remains genuinely unresolved rather than merely thinly sourced: French lawmakers have not finalised applicable rules governing crypto-related social media influencer promotions. This was last documented as an unsettled grey area in 2023 reporting and has not been reconfirmed as either resolved or still pending in this cycle's research pass, leaving it a residual gap within the broader DASP/CASP consumer-protection framework.

Outlook

Two threads merit tracking. First, whether stronger primary sourcing emerges for the custody-segregation and complaint-handling obligations to restore Confirmed-tier confidence. Second, and more substantively, whether French authorities (the AMF or the consumer-protection authority DGCCRF) issue a definitive current position on influencer marketing rules for crypto promotions, an area that has sat unresolved in the public record since at least 2023.

The more significant recent development is the entry into force of DAC8 crypto-tax reporting. A DGFiP-administered French implementing decree now requires crypto-asset service providers operating in France to conduct due diligence and report user transaction data under Code Général des Impôts Articles 1649 AC bis through sexies, with declarations covering calendar-year 2026 transactions due from CASPs starting in 2027. This obligation is now in force as of 1 January 2026. However, a Challenger flag has surfaced an unresolved question regarding the correct legal-instrument attribution: it contends that these CGI articles were in fact created by Article 54 of the Loi de finances pour 2025 (Law No. 2025-127 of 14 February 2025), with the December 2025 decree(s) functioning only as implementing modalities rather than the primary transposition vehicle for DAC8. This contention has been annotated in the record but not used to mutate the claim, because the sources supporting it are secondary (trade-press) only, set against a primary EUR-Lex/Journal officiel anchor for the original claim; it therefore remains an open item pending verification against the statute text itself.

The underlying EU directive, Council Directive (EU) 2023/2226 (DAC8), separately requires crypto-asset service providers to bring their reporting systems, customer due-diligence processes and internal controls into full compliance by 1 July of the applicable year. This claim rested solely on a single trade-press source and has been downgraded to Probable this cycle in line with the thin-evidence-module sourcing standard applied to tax_treatment.

Outlook

Two verification items should take priority in the next research cycle: confirming or resolving the decree-versus-statute legal-instrument attribution question for the CGI DAC8 reporting articles against the primary text of the Loi de finances pour 2025, and reconfirming the current flat-tax percentage and threshold rules for occasional individual crypto-asset capital gains directly against impots.gouv.fr. Both items currently limit how far this module's claims can be relied upon at Confirmed-tier confidence.

On the other side of the same perimeter, an AMF-authorised CASP benefits from EU-wide passporting rights, permitting cross-border provision of crypto-asset services throughout the EU without the need for separate host-state authorisation in each member state. This materiality-4 binding claim rested solely on a single trade-press source in what is, for this claim, a thin-evidence module, and has been downgraded to Probable this cycle pending a stronger primary ESMA or AMF citation.

On the tax-reporting side, the French DAC8-implementing decree requires reporting crypto-asset service providers to identify and report on crypto-asset users linked to partner states or non-EU territories that maintain an information-exchange agreement with France. This claim shares the same legal-instrument attribution question flagged in the tax_treatment module: whether the December 2025 decree or the earlier February 2025 Loi de finances is properly the primary transposition vehicle for these obligations remains unresolved pending verification against the statute text.

Outlook

The passporting-rights claim would benefit most directly from a stronger primary source in the next cycle, given its materiality and its current downgrade to Probable. The cross-border DAC8 reporting obligations should be watched alongside the parallel tax_treatment module for resolution of the shared legal-instrument attribution question, since both claims stand or fall together on that point.