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title: "France Crypto Regulation Monitor | cryptoassets.gi"
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description: "France crypto asset regulation: 9 categories, 83 sourced findings, updated 2026-11-04. Licensing, token classification, stablecoins, tax treatment."
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# France Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed regulated overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/france/), [World Payments](https://payments.gi/jurisdictions/france/)

Last updated 2026-11-04 · 9 categories · 83 sourced
findings · 88 sources in the cumulative register

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Evidence re-verified: 2026-11-04 · Position last changed: 2026-11-04 · Record history & provenance &#9662; Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

[Open in Co-Pilot &#8599;](/reports/?type=copilot&j=FRANCE)[Build Report](/reports/?j=FRANCE)[Compare](/compare/?j=FRANCE)

Framework posture Regulated 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority AMF Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) 2027-Q1 Amendment I-3898 crypto-to-EMT taxable-disposal rule — further legislative stages

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

9 Categories

0 Moved this cycle 0 Key judgments 2 Open gaps 83 Findings

15 Tier-1 sources

Confidence mix 9 unpopulated
(sums to 9 rendered categories; click to filter)

No categories moved this cycle.

Law made at European Economic Area (Bloc) level that applies in France is covered once, on the [European Economic Area (Bloc)](/jurisdictions/european-economic-area-bloc/) page. This page covers France&#8217;s own layer: implementation, national authorities, national options and local enforcement.

## Jurisdiction lead brief

###### Latest update · 20 October 2026

#### Lead Signal

France&#x27;s crypto-asset regulatory environment continues to operate under the fully commenced Markets in Crypto-Assets regime, with the national transitional registration pathway for crypto-asset providers now closed since 1 July 2026. Against that stable backdrop, the most notable development sits in the stablecoin space, where Banque de France guidance published on 1 October 2026 draws a doctrinal distinction between privately-issued, fiat-pegged stablecoins and central-bank digital currency for monetary-sovereignty purposes. This is a policy-framing development rather than a licensing rule change, and it is understood to carry probable rather than confirmed status given its sourcing.

The guidance matters because it signals how France&#x27;s central bank is positioning stablecoins within its broader thinking about monetary sovereignty, even though the Banque de France is not itself the licensing authority for crypto-asset service providers or stablecoin issuers; that role sits with the Autorite des Marches Financiers for authorisation and the Autorite de Controle Prudentiel et de Resolution for prudential co-approval of payment-adjacent firms.

#### Other Developments

Banque de France articulates a stablecoin-versus-CBDC distinction. The guidance frames privately-issued, fiat-pegged stablecoins as a category distinct from any central-bank digital currency on monetary-sovereignty grounds. This is doctrinal commentary from the central bank rather than a supervisory or licensing instrument, and it does not itself alter the authorisation requirements that apply to stablecoin issuers or crypto-asset service providers under the European framework. Its practical effect is to shape the policy conversation around how euro-denominated stablecoins are discussed in France, rather than to create or remove any compliance obligation.

Core EMT and ART rules remain the operative framework. The European electronic-money-token and asset-referenced-token categories established under the Markets in Crypto-Assets regulation continue to be the applicable rules for stablecoin issuance touching France, with the Autorite de Controle Prudentiel et de Resolution continuing its role in co-approving crypto-asset service provider applications that touch stablecoin-adjacent payment firms. No independently confirmed first authorised euro-denominated stablecoin issuer under the European framework in France was identified.

#### Cross-Monitor Connections

The stablecoin doctrine development sits alongside, but is distinct from, the broader financial-integrity enforcement activity visible in France, where the securities regulator has continued its quarterly publication of unauthorised crypto-asset provider warnings. Both signals point to the same underlying fact: France&#x27;s digital-asset regulatory architecture, now fully transitioned to the European framework, is being actively worked by multiple authorities, each from its own institutional angle, rather than left dormant following the formal transition date.

#### Outlook

The Banque de France&#x27;s doctrinal framing of stablecoins relative to central-bank digital currency is likely to continue developing as a policy position rather than crystallising into a binding rule in the near term, since the central bank does not hold direct licensing authority over stablecoin issuers. The more consequential development to watch remains whether and when a euro-denominated stablecoin issuer achieves confirmed authorisation under the European framework in France, which would mark a concrete milestone against the currently probable-only doctrinal signal recorded.

5 earlier updates not shown here.

###### Standing brief · as of 3 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

The single most consequential development in this cycle is confirmation that the European Union&#x27;s MiCA Article 143 grandfathering period, the transitional mechanism that had allowed France&#x27;s pre-existing PSAN-registered digital asset service providers to keep operating without a full Crypto-Asset Service Provider licence, expired on 1 July 2026. That expiry converts CASP authorisation under MiCA Articles 59 and 60 from one of two co-existing legal bases into the sole operative licensing pathway for anyone providing crypto-asset services to French or EU clients, and ESMA has stated publicly that unauthorised providers must now wind down EU client-facing activity in an orderly fashion. This closes out close to two years of dual-regime coexistence between the national PACTE Law PSAN registration created in 2019 and the newer EU-wide MiCA authorisation, and it hardens the practical stakes of authorisation status for every firm still serving French clients. Underlying this headline, however, sits a sourcing correction worth flagging on its own terms: the underlying claim establishing the AMF&#x27;s core CASP-authorisation requirement had, on review, rested solely on a single trade-press report rather than a primary regulatory source, and has this cycle been re-anchored to ESMA&#x27;s own MiCA overview page, with confidence correspondingly adjusted downward from Confirmed to Probable under the two-anchor standard for Confirmed-tier claims. A parallel correction applied to the AMF&#x27;s custody-segregation obligation for licensed providers. Readers should treat the underlying legal requirement itself as well-established -- MiCA is a settled, force-of-law EU regulation -- while noting that this cycle&#x27;s confidence labelling reflects sourcing discipline rather than any softening of the rule itself. A live licensing data point illustrates the regime in action: SwissBorg&#x27;s French entity, BlockNodes SAS, obtained full MiCA CASP authorisation from the AMF spanning custody, execution, transfer/placing, portfolio management and advice services, with the AMF&#x27;s own white-list register fixing the grant date seven days earlier than the date reported in press coverage.

#### Other Developments

Beyond licensing, France&#x27;s token-classification regime remains settled and increasingly demonstrated in practice: named e-money-token issuers including SG-FORGE, Circle Internet Financial Europe and Schuman Financial operate under ACPR electronic-money-institution authorisation and MiCA Title IV, NFTs remain excluded from MiCA&#x27;s scope by the regulation&#x27;s own text, and ESMA&#x27;s substance-over-form three-criteria test continues to govern the boundary between MiCA-scoped crypto-assets and MiFID II transferable securities. The on-chain activity picture is more mixed: ESMA and EBA&#x27;s own Article 142 joint analysis confirms that self-custodial wallets and DeFi lending or staking protocols generally sit outside MiCA&#x27;s authorisation and AML/CFT perimeter absent an identifiable intermediary, sustaining a genuine EU-wide regulatory gap that is not a France-specific omission, even as a new Banque de France/Treasury/AMF strategic group on DLT and tokenisation has been formed without yet producing binding output. France&#x27;s stablecoin market continues to operate actively under the MiCA e-money-token framework, with SG-FORGE&#x27;s EURCV and USDCV and Schuman Financial&#x27;s EURØP representing concrete examples of authorised issuance, reserve segregation and par-value redemption rights; however, this cycle&#x27;s sourcing review found that several of these binding claims -- issuance authorisation, reserve backing, and redemption rights -- rested solely on trade-press or price-tracker sourcing, prompting a confidence downgrade to Probable across the board pending stronger primary ACPR or EBA citations. Separately, Banque de France leadership continues to advocate strengthening MiCA to restrict non-bank and non-EU stablecoin use in everyday payments on counterparty-risk grounds, though this remains an advocacy position rather than enacted law. On consumer protection, core custody-segregation and complaint-handling obligations remain in force, subject to the same sourcing re-anchoring exercise, while the treatment of crypto-related social media influencer promotions remains a genuinely unresolved grey area last confirmed unsettled in 2023 reporting. Tax treatment shows the clearest forward motion this cycle: DAC8 crypto-tax reporting obligations are now in force from 1 January 2026, with first declarations covering 2026 transactions due from CASPs in 2027, though a legal-instrument attribution question has surfaced regarding whether the operative transposition vehicle is the December 2025 implementing decree or an earlier February 2025 statute, a question that remains unresolved pending stronger primary sourcing. Cross-border transfer rules remain settled, with non-EU CASPs barred from lawfully soliciting French or EU clients outside narrow reverse-solicitation, AMF-authorised CASPs continuing to benefit from EU-wide passporting, and the same DAC8 decree extending cross-border tax-information-exchange reporting obligations to partner-state-linked users.

#### Cross-Monitor Connections

Two overlap channels are active this cycle. AML/CFT supervision of French crypto-asset service providers -- covering KYC/CDD, the travel rule, and SAR/STR reporting, jointly exercised by TRACFIN and the ACPR -- continues to be treated as a subscribed surface consumed from the Financial Integrity Monitor&#x27;s own analysis rather than an area of original crypto-monitor findings, meaning readers tracking anti-money-laundering exposure for French crypto firms should look to that monitor&#x27;s own cycle output for substantive detail. Separately, this cycle&#x27;s stablecoin and tax developments both carry payments-adjacent relevance for the World Payments Monitor: Banque de France&#x27;s advocacy to restrict non-bank and non-EU stablecoin use in everyday payments speaks directly to payment-rail policy debates beyond crypto-specific regulation, while the DAC8 cross-border tax-information-exchange reporting regime touches the same cross-border payments-data infrastructure that monitor tracks independently.

#### Outlook

Several threads remain open heading into the next cycle. The legal-instrument attribution question around DAC8&#x27;s French transposition -- decree versus statute -- awaits confirmation against the primary text of the Loi de finances pour 2025. The precise current flat-tax percentage applicable to occasional individual crypto capital gains has not been reconfirmed against a live DGFiP source and should be revisited before any tax-facing guidance is drawn from this record. France&#x27;s lawmakers&#x27; final position on influencer marketing rules for crypto promotions remains unconfirmed since 2023. Most structurally, a metadata-level contradiction was identified this cycle between the record&#x27;s own source-tier counters, which reported zero Tier-1, Tier-2 or Tier-3 sources, and the underlying source register and claim set, which in fact cite five Tier-1 sources and one Tier-2 source supporting several Confirmed-tier claims; this discrepancy has been escalated for human verification and is the basis for holding this record pending confirmation that confidence calibration across the cycle was performed against an accurate accounting of source tiers.

Read full brief · 1513 words

Key regulatory facts for France Regulatory Dimension France Standing Position

Jurisdiction France (FR)

Regulatory Scope Crypto & Digital Asset Regulation (9 modules, 83 sourced findings)

Crypto Licensing France&#x27;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&#x27;s original PSAN/DASP registration regime.

Token Classification France applies MiCA&#x27;s tripartite crypto-asset taxonomy -- asset-referenced tokens, e-money tokens and other/utility crypto-assets -- as its operative classification framework, layered atop the PACTE Law&#x27;s earlier ICO...

On-Chain Activity Regime On-chain activity oversight in France remains split between a settled custodial perimeter and an acknowledged gap for non-custodial activity.

Stablecoin Regime France operates an active euro/dollar e-money-token stablecoin market under MiCA&#x27;s Title III/IV framework and the pre-existing EMD2 regime.

Primary Instruments Cited AMF, MiCA Article 143 grandfathering regime, France (PACTE Law 2019), SwissBorg / BlockNodes SAS, AMF

Last Confirmed / Updated 2026-11-04 (88 sources in cumulative register)

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### France: C1 Crypto LicensingGreenEnacted in forceModule confidence: Probable&#9662;

France&#x27;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&#x27;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&#x27;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&#x27;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&#x27;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&#x27;s own white-list register entry.

Open gap — crypto-int-2 France&#x27;s existing flat-tax regime for occasional crypto disposals (Art. 150 VH bis CGI) was not independently re-verified against primary tax instrument this cycle. no under-indexing note recorded

Horizon · 2026-07-01 (± a quarter) MiCA CASP transition period ends for French PSANs In force · Tier 1 source

Horizon · 2026-07-01 (± a quarter) MiCA CASP transition period ends for French PSANs In force · Tier 1 source

#### Crypto Licensing

France&#x27;s crypto-asset licensing regime sits squarely within the EU&#x27;s Markets in Crypto-Assets Regulation (MiCA), administered domestically by the Autorité des Marchés Financiers, with the 2019 PACTE Law&#x27;s original digital asset service provider (PSAN/DASP) registration regime as its national-law foundation. The AMF requires CASP authorisation under MiCA Articles 59 and 60 before any entity may lawfully provide crypto-asset services in France or elsewhere in the EU. This cycle, review found that the underlying claim establishing this authorisation requirement had rested solely on a single trade-press report rather than a primary regulatory citation; it has been re-anchored to ESMA&#x27;s own MiCA overview page, and confidence has been adjusted from Confirmed to Probable in line with the two-anchor standard applied to Confirmed-tier claims. This is a sourcing correction rather than any softening of the underlying legal requirement, which remains a settled feature of EU law.

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&#x27;s national PSAN registration and the EU&#x27;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&#x27;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&#x27;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&#x27;s review corrected the recorded grant date: the AMF&#x27;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&#x27; 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&#x27;s grandfathering-periods list this cycle and remains a documented gap for the next research pass.

Read full sub-brief · 476 words Periodic update · new data 2026-10-18

#### Crypto Licensing

France&#x27;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&#x27; 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&#x27;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) Periodic update · new data 2026-10-06

#### Crypto Licensing

France&#x27;s national transitional bridge from its pre-existing PSAN (Prestataire de Services sur Actifs Numériques) registration regime to full authorisation under the EU&#x27;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&#x27;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&#x27;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&#x27;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&#x27; 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&#x27;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&#x27;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&#x27;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&#x27;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.

Periodic update · new data 2026-10-05

#### Crypto Licensing

France&#x27;s national PSAN registration regime ceased to authorise new entrants when the MiCA transitional window closed on 1 July 2026. The AMF&#x27;s own confirmation states that digital asset service providers engaged in crypto-asset service provision before MiCA&#x27;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&#x27;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&#x27;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.

Periodic update · new data 2026-09-21

#### Crypto Licensing

France&#x27;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&#x27;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&#x27; 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.

Periodic update · new data 2026-09-13

#### Crypto Licensing

France&#x27;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&#x27;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.

Periodic update · new data 2026-08-25

#### Crypto Licensing

France&#x27;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&#x27;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 (25)
- T1 · ESMA[AMF](https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica) — CASP authorisation under MiCA Articles 59/60 before lawfully providing crypto-asset services in France and the EU
- T1 · ESMA[MiCA Article 143 grandfathering regime](https://www.esma.europa.eu/sites/default/files/2026-04/ESMA75-113276571-1679_Statement_on_the_end_of_transitional_periods_under_MiCA.pdf) — 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 activity
- T1 · Bank for International Settlements (republishing Banque de France speech)[France (PACTE Law 2019)](https://www.bis.org/review/r260331b.htm) — a dedicated national registration/licensing regime for digital asset service providers (PSAN/DASP)
- T1 · Autorité des Marchés Financiers (AMF)[SwissBorg / BlockNodes SAS](https://www.amf-france.org/en/warnings/white-lists/daspcasp/blocknodes-sas) — full MiCA CASP authorisation from the AMF, covering custody, execution, transfer/placing, portfolio management and advice services
- T3[AMF](https://bleulexlaw.com/guides/agrement-psca-mica/) — MiCA CASP authorisation for providing crypto-asset services in France; PSAN regime ended 1 July 2026
- T3[France crypto-asset service provision](https://www.amf-france.org/en/news-publications/news/mica-regulation-amf-now-accepting-applications-authorisation-casp) — From 1 July 2026, crypto-asset services may be provided in France only via MiCA CASP authorisation (AMF) or the Article 60 notification route
- T1[AMF](https://www.amf-france.org/en/news-publications/news-releases/amf-news-releases/crypto-assets-autorite-des-marches-financiers-warns-public-about-activities-several-unauthorized-3) — Quarterly blacklist of unauthorised crypto-asset websites; 26 names added 19 Oct 2026, 2026 total 64
- T1 · Autorité des marchés financiers (AMF)[CASP authorisation requirement (MiCA Art. 59/63)](https://www.amf-france.org/en/news-publications/depth/mica) — AMF (with ACPR opinion), effective 2024-12-30
- T3 · Bleu Lex Law[PSAN transitional registration regime](https://bleulexlaw.com/en/guides/casp-authorisation-mica/) — 2026-06-30
- T3 · Legal Nodes[MiCA Art 111(3) administrative fine ceiling for legal persons](https://www.legalnodes.com/article/mica-regulation-explained) — EUR 5,000,000 or turnover percentage (3%/12.5%/5% depending on breach)
- T3 · Fibo Crypto[CMF L.54-10-4 / L.572-23 criminal offence for unauthorised crypto-asset service provision](https://fibo-crypto.fr/blog/amf-ultimatum-mica-psan-france-juillet-2026/) — providing crypto-asset services without CASP authorisation
- T1[offeror or person seeking admission to trading](https://www.amf-france.org/en/professionals/fintech/my-relations-amf/public-offerings-and-admission-trading-crypto-assets) — pay a fixed fee of EUR 3,000 to the AMF for white-paper notification
- T1[person providing crypto-asset services](https://www.amf-france.org/en/news-publications/depth/mica) — only an authorised CASP may provide crypto-asset services in France from 30 December 2024
- T3[AMF (competent authority)](https://bleulexlaw.com/en/guides/casp-authorisation-mica/) — checks completeness within ~25 working days; decides within ~40 working days of complete file, after ACPR opinion
- T3[already-regulated financial entity](https://www.legalnodes.com/article/mica-regulation-explained) — may provide crypto-asset services by notifying competent authority at least 40 working days in advance, instead of full CASP authorisation
- T3[registered PSAN](https://bleulexlaw.com/en/guides/casp-authorisation-mica/) — PSAN registration closed to new entrants from 30 December 2024; transitional continuation deadline was 30 June 2026
- T2[PSAN not completing MiCA transition](https://www.france-epargne.fr/news/mica-deadline-amf-90-prestataires-crypto-france-juillet-2026) — AMF recommended orderly cessation from 30 March 2026; those not authorised by 2 July 2026 struck off (e.g. Binance France SAS)
- T3[CASP / ART issuer](https://www.regulation-dora.eu/crypto-casp) — CASPs and ART issuers are financial entities within DORA scope, subject to ICT risk-management, incident-reporting, resilience-testing and third-party-oversight rules
- T3[CASP](https://www.circuitsecurity.com/learn/eu-mica-dora) — classify and report major ICT incidents: initial notification within 4 hours of classification (max 24h after awareness); intermediate report within 72 hours; final report within 1 month
- T3[CASP](https://www.orbiqhq.com/eu-regulations/dora-compliance) — maintain and annually review a register of ICT third-party contractual arrangements
- T3[https://www.legalnodes.com/article/mica-regulation-explained](https://www.legalnodes.com/article/mica-regulation-explained) — legal persons: fines of at least EUR 5,000,000 plus turnover-based alternative (3% issuance breaches, 12.5% ART/EMT breaches, 5% CASP breaches)
- T3[https://www.mica.wtf/mica/title-vii-competent-authorities-eba-and-esma-art.-93-138/chapter-3/article-111](https://www.mica.wtf/mica/title-vii-competent-authorities-eba-and-esma-art.-93-138/chapter-3/article-111) — market-abuse infringements (Arts 89-92): legal-person fines up to EUR 15,000,000 or 15% turnover; Art 88 disclosure breaches: EUR 2,500,000 or 2% turnover
- T1[AMF Commission des sanctions](https://www.legifrance.gouv.fr/codes/id/LEGISCTA000006184941) — French implementing regime exceeds the MiCA floor: pecuniary sanctions up to EUR 100,000,000 or ten times the advantage gained (legal persons), EUR 15,000,000 (natural persons), or up to 15% of annual turnover for market-abuse-type breaches
- T3[unauthorised crypto-asset service provider](https://fibo-crypto.fr/blog/amf-ultimatum-mica-psan-france-juillet-2026/) — criminal offence: up to 2 years&#x27; imprisonment and EUR 30,000 fine for providing crypto-asset services without CASP authorisation
- T3[CASP](https://voixa.es/en/insights/mica-casp-capital-requirements/) — hold prudential safeguards at the higher of Annex IV permanent minimum capital for its service class, and one quarter of preceding year&#x27;s fixed overheads

### France: C2 Token ClassificationGreenEnacted in forceModule confidence: Probable&#9662;

France applies MiCA&#x27;s tripartite crypto-asset taxonomy -- asset-referenced tokens, e-money tokens and other/utility crypto-assets -- as its operative classification framework, layered atop the PACTE Law&#x27;s earlier ICO visa regime. The ACPR requires e-money token issuers, including SG-FORGE, Circle Internet Financial Europe and Schuman Financial, to hold electronic money institution authorisation and comply with MiCA Title IV, per ESMA&#x27;s Interim MiCA EMT White Paper register. The PACTE-era AMF ICO visa regime continues to restrict eligible public offerings to utility tokens that do not qualify as financial instruments, though this claim&#x27;s sourcing remains below the materiality-4 chase-protocol threshold and rests on a single trade-press anchor pending a stronger primary source. For instruments at the classification boundary, ESMA directs national competent authorities to apply a substance-over-form, three-criteria test to determine when a crypto-asset qualifies as a MiFID II transferable security and therefore falls outside MiCA&#x27;s scope. NFTs -- crypto-assets that are unique and non-fungible with other crypto-assets -- are excluded from MiCA&#x27;s scope under Article 2, per the regulation&#x27;s own text.

Horizon · 2027-Q1 (± six months) Amendment I-3898 crypto-to-EMT taxable-disposal rule — further legislative stages Proposed · Tier 3 source

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-04

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### France: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable&#9662;

On-chain activity oversight in France remains split between a settled custodial perimeter and an acknowledged gap for non-custodial activity. ESMA&#x27;s Q&A 2067 addresses the treatment of staking-as-a-service offered by authorised CASPs as a custody-adjacent obligation, though this guidance page carries no independent publication date and the module remains thin on evidence. More significantly, ESMA and EBA&#x27;s own Article 142 MiCA Joint Report finds that self-custodial wallets and DeFi lending/staking protocols are not generally subject to MiCA authorisation or AML/CFT requirements absent an identifiable intermediary -- a negative finding that leaves a genuine, EU-wide regulatory gap for non-custodial DeFi rather than a France-specific omission. Separately, the Banque de France, French Treasury and AMF have formed a joint strategic group dedicated to DLT and tokenisation innovation; this is a non-normative institutional development and does not yet constitute binding tokenisation-specific rules.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

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### France: C4 Stablecoin RegimeGreenEnacted in forceModule confidence: Probable&#9662;

France operates an active euro/dollar e-money-token stablecoin market under MiCA&#x27;s Title III/IV framework and the pre-existing EMD2 regime. The ACPR requires EMT issuance in France to carry electronic money institution authorisation, as evidenced by SG-FORGE&#x27;s EURCV/USDCV and Schuman Financial&#x27;s EURØP licences; this materiality-5 binding claim, along with the related reserve-backing and redemption-right claims, rested solely on trade-press or price-tracker sourcing and has been downgraded this cycle from Confirmed to Probable pending stronger primary ACPR/EBA anchoring, consistent with the thin-evidence-module sourcing bar applied to stablecoin_regime. SG-FORGE&#x27;s EURCV and USDCV tokens are represented as backed by fully segregated fiat reserves held at regulated custodian banks -- Société Générale for EUR, BNY Mellon for USD -- consistent with MiCA&#x27;s EMT reserve rules, and EURCV holders in the EEA are represented as entitled to redeem tokens at par value directly from SG-FORGE or via approved partners, in line with MiCA Article 49&#x27;s redemption-right requirements. Separately, Banque de France leadership has advocated strengthening MiCA to restrict the use of non-bank and non-EU stablecoins for everyday payments, citing counterparty-risk concerns; this remains a policy proposal with no enacted instrument behind it.

Periodic update · new data 2026-10-20

#### Stablecoin Regime

The stablecoin regime in France continues to operate under the core electronic-money-token and asset-referenced-token provisions of the European Markets in Crypto-Assets regulation, with the Autorite de Controle Prudentiel et de Resolution holding the prudential supervisory role and continuing to co-approve crypto-asset service provider applications that touch stablecoin-adjacent payment firms. The development is doctrinal rather than regulatory: on 1 October 2026, the Banque de France issued guidance drawing a distinction between privately-issued, fiat-pegged stablecoins and any central-bank digital currency, framed in terms of monetary sovereignty. The distinction is understood to carry probable confidence, given that it rests on commentary reporting on the Banque de France&#x27;s position rather than on a primary instrument independently re-verified.

It is important to be precise about what this guidance does and does not do. The Banque de France is France&#x27;s central bank and plays an advisory and monetary-policy role in the digital-asset space, but it is not the licensing or supervisory authority for crypto-asset service providers or for stablecoin issuers under the European framework; those functions sit respectively with the securities regulator for crypto-asset service provider authorisation and with the prudential authority for the banking and payment-institution dimensions of stablecoin-adjacent firms. The guidance therefore should be read as shaping the policy and public conversation around stablecoins in France, particularly on questions of monetary sovereignty and the relationship between privately-issued stablecoins and any future central-bank digital currency, rather than as altering any issuer&#x27;s authorisation obligations.

No independently confirmed instance of a euro-denominated stablecoin issuer achieving authorisation under the core electronic-money-token or asset-referenced-token provisions in France was identified. The underlying legal framework for such authorisation, found in Titles III and IV of the European Markets in Crypto-Assets regulation, remains unchanged and continues to apply directly. The absence of a confirmed authorised issuer is not itself evidence of a gap in the regime; it reflects the state of the market and sourcing available rather than a finding about the regime&#x27;s adequacy.

The practical significance of the Banque de France&#x27;s framing lies in its signalling value for how French monetary authorities conceptualise the stablecoin space relative to sovereign digital currency ambitions. For market participants and prudential counterparties, the key operative facts remain unchanged: issuance and service provision in France continue to be governed by the European framework&#x27;s electronic-money-token and asset-referenced-token rules, administered through the securities regulator and prudential authority, with the central bank contributing doctrinal and monetary-policy perspective rather than direct supervision.

#### Outlook

The doctrinal distinction articulated by the Banque de France is likely to continue evolving as a policy position over coming cycles, particularly as European-level discussion of a digital euro progresses, but it is not expected to translate into a binding licensing rule change in the near term given the central bank&#x27;s role is advisory rather than supervisory in this space. Watch for independent confirmation of any euro-denominated stablecoin issuer achieving authorisation under the core electronic-money-token or asset-referenced-token provisions in France, which would represent a concrete milestone distinct from the doctrinal-only development, and for any evolution in how the prudential authority&#x27;s co-approval role interacts with stablecoin-adjacent payment-institution applications.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 7 traced claims · Re-verified 2026-11-04

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### France: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable&#9662;

Consumer protection for French crypto-asset users rests on AMF-administered custody, complaint-handling and disclosure obligations layered onto MiCA. The AMF requires DASPs/CASPs licensed in France to maintain custody arrangements segregating client assets from the firm&#x27;s own assets, prohibiting use of client assets without express prior consent; following a Challenger flag, this materiality-5 binding claim was re-anchored from a sole T4 trade-press source to ESMA&#x27;s T1 MiCA overview page, with confidence correspondingly downgraded to Probable. Licensed French digital-asset custodians are also required to maintain a claims/complaint-handling procedure, compensating clients where the custodian cannot restore control of client assets -- a claim likewise downgraded to Probable this cycle for resting solely on a T4 source. On disclosure, ESMA directs EU and French consumers to verify a CASP&#x27;s authorisation status in the ESMA Interim MiCA Register before investing, since MiCA protections apply only to the specific authorised legal entity. One area remains genuinely unsettled: French lawmakers have not finalised applicable rules for crypto-related social media influencer promotions, a residual grey area within the broader DASP/CASP consumer-protection framework that was last confirmed unsettled in 2023 reporting and has not been reconfirmed this pass.

Open gap — crypto-int-1 No France-specific staking, DeFi, mining, node-operation or tokenisation rule distinct from MiCA/EU level was identified this cycle. no under-indexing note recorded

#### Consumer Protection

Consumer protection for crypto-asset users in France combines AMF-administered custody and complaint-handling obligations with EU-level disclosure requirements under MiCA. The AMF requires DASPs and CASPs licensed in France to maintain custody arrangements that segregate client assets from the firm&#x27;s own assets, and prohibits use of client assets without express prior consent. Following a Challenger flag identifying that this materiality-5 binding claim rested solely on a single trade-press source, it has been re-anchored this cycle to ESMA&#x27;s own T1 MiCA overview page, with confidence correspondingly adjusted from Confirmed to Probable.

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&#x27;s authorisation status directly in the ESMA Interim MiCA Register before investing, since MiCA&#x27;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&#x27;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&#x27;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.

Read full sub-brief · 338 words Periodic update · new data 2026-08-25

#### Consumer Protection

France&#x27;s crypto consumer-protection framework this cycle is dominated by the wind-down obligations attached to the MiCA cutover. DASPs anticipating that they will be unable to continue operating in compliance with MiCA after 1 July 2026 are required to implement an orderly-cessation plan, and since 30 March 2026 only strictly necessary wind-down operations have been permitted for such firms. This is a direct investor-protection mechanism: rather than allowing a non-compliant operator to simply cease servicing clients at the cutover date, the framework requires a structured, planned exit intended to protect client assets and positions during the transition out of the regulated perimeter.

This obligation sits downstream of the licensing cutover covered under Crypto Licensing, and its practical significance depends on how many of the roughly 90 legacy PSAN/DASP firms facing the 30 June 2026 deadline elect an orderly-cessation path rather than pursuing continued MiCA authorisation. The consumer-protection framework is assessed at amber traffic-light status: the wind-down mechanism is now active and enforced against a defined population, but its coverage is concentrated on the exiting-operator cohort specifically, rather than reflecting a broader consumer-protection development across the market as a whole.

#### Outlook

The marker to watch is whether AMF publishes any indication of how many DASPs have actually invoked the orderly-cessation mechanism, which would clarify the practical scale of this consumer-protection safeguard relative to the licensing cutover&#x27;s broader enforcement activity.

Sources and findings (21)
- T1 · ESMA[AMF](https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica) — DASPs/CASPs licensed in France to maintain custody provisions segregating client assets from the firm&#x27;s own assets, prohibited from using client assets without express prior consent
- T3 · CoinDesk[Licensed French digital asset custodians](https://www.coindesk.com/policy/2019/12/26/crypto-firms-can-now-apply-for-a-license-in-france/) — a claims/complaint handling procedure, compensating clients where the custodian cannot restore control of client assets
- T1[ESMA](https://www.esma.europa.eu/sites/default/files/2026-04/ESMA75-113276571-1679_Statement_on_the_end_of_transitional_periods_under_MiCA.pdf) — EU/French consumers to verify a CASP&#x27;s authorisation status in the ESMA Interim MiCA Register before investing, given MiCA protections apply only to the specific authorised legal entity
- T3 · CoinDesk[French lawmakers](https://www.coindesk.com/policy/2023/05/17/fleeing-us-crypto-firms-welcome-french-regulator-says) — applicable rules for crypto-related social media influencer promotions, leaving this a residual grey area within the broader DASP/CASP consumer-protection framework
- T1[AMF-authorised CASPs](https://www.amf-france.org/en/news-publications/news/mica-regulation-amf-now-accepting-applications-authorisation-casp) — MiCA custody and safeguarding rules (Art. 75) apply directly to AMF-authorised CASPs; no France-specific guidance or enforcement located this cycle
- T1[MiCA Title VI (Arts 86-92)](https://www.amf-france.org/en/news-publications/news-releases/crypto-assets-end-pacte-law-and-european-mica-regulation-transitional-period-establishes-new-role) — Market-abuse prohibitions (insider dealing, unlawful disclosure, market manipulation) apply directly to crypto-assets admitted to trading, enforced in France by the AMF.
- T3 · Headless Law[CASP custody segregation duty (MiCA Art. 75)](https://www.headlesslaw.com/mica/articles/75) — client crypto-asset holdings from CASP&#x27;s own holdings
- T3 · MyComplianceOffice[MiCA market-abuse regime (Title VI)](https://mco.mycomplianceoffice.com/blog/mica-and-insider-risk-what-crypto-firms-need-to-know) — insider dealing and market manipulation in crypto-assets admitted to trading
- T3 · Springlex[Regulation (EU) 2023/1114 (MiCA), Art. 71](https://www.springlex.eu/fr/packages/mica/mica-regulation/article-71/) — effective, transparent complaint-handling procedures, free of charge, with published description, standard template and complaint record-keeping
- T1 · Autorité des marchés financiers (AMF)[AMF Instruction-recommandation DOC-2012-07](https://www.amf-france.org/sites/institutionnel/files/private/2024-02/synthese-spot-traitement-des-reclamations_02.02_0.pdf) — complaint acknowledgment within 10 business days and substantive reply within 2 months maximum, barring duly justified special circumstances
- T1 · Autorité des marchés financiers (AMF)[AMF Médiateur procedure](https://www.amf-france.org/sites/institutionnel/files/contenu_simple/guide/guide_pedagogique/S&#x27;informer%20sur%20%20Le%20Mediateur%20de%20l&#x27;AMF.pdf) — free dispute mediation generally within 1 year of the written complaint, with a recommendation issued within 90 days of receiving all relevant elements
- T3[CASP (custody and administration)](https://www.headlesslaw.com/mica/articles/75) — establish a custody policy with internal rules and procedures to ensure the safekeeping or control of crypto-assets or the means of access to them
- T3[CASP (custody and administration)](https://www.springlex.eu/en/packages/mica/mica-regulation/article-75/) — segregate client crypto-asset holdings from its own holdings; client holdings not available to CASP creditors on insolvency
- T3[CASP holding client funds](https://safeheld.com/resources/what-is-mica) — place client funds by end of next business day with a credit institution or central bank, kept separately identified from own funds
- T3[any person](https://blog.bcas.io/market-abuse-prevention-mica-title-vi) — MiCA market-abuse Title VI applies to acts concerning crypto-assets admitted to trading or for which admission has been requested
- T3[any person](https://mco.mycomplianceoffice.com/blog/mica-and-insider-risk-what-crypto-firms-need-to-know) — insider dealing/use of inside information to trade, cancel or amend orders in crypto-assets, or to recommend others do so
- T3[any person](https://gomica.eu/mica/market-abuse) — market manipulation of crypto-assets (false/misleading signals as to supply, demand or price) unless for legitimate reasons
- T3[person professionally arranging/executing crypto-asset transactions](https://crixta.com/en/crypto-market-abuse-explained-manipulation-insider-trading-surveillance/) — maintain effective arrangements, systems and procedures to prevent and detect market abuse, and report reasonable suspicions
- T1[ESMA / competent authorities](https://www.esma.europa.eu/sites/default/files/2025-04/ESMA75-453128700-1408_Final_Report_MiCA_Guidelines_on_prevention_and_detection_of_market_abuse.pdf) — ESMA guidelines on market-abuse supervisory practices under MiCA Title VI, issued by 30 June 2025
- T1[offeror or person seeking admission to trading](https://www.amf-france.org/en/professionals/fintech/my-relations-amf/public-offerings-and-admission-trading-crypto-assets) — notify modified white paper/marketing communication to AMF at least 7 working days before publication
- T1[offeror or person seeking admission to trading](https://www.amf-france.org/en/professionals/fintech/my-relations-amf/public-offerings-and-admission-trading-crypto-assets) — notify crypto-asset white paper to AMF at least 20 working days before intended publication, with explanation of token classification

### France: C6 Tax TreatmentGreenEnacted in forceModule confidence: Probable&#9662;

French crypto-asset taxation combines a long-settled capital-gains basis with newly operative cross-border reporting obligations. The French Council of State ruled that occasional individual investors&#x27; crypto-asset disposal gains are taxed as capital gains on movable property rather than at the higher industrial/commercial or non-commercial profits rates; this foundational 2018/2019 ruling remains the operative basis, though the current precise flat-tax percentage has not been reconfirmed against a live primary source this pass. More recently, a DGFiP-administered French DAC8 implementing decree requires crypto-asset service providers operating in France to conduct due diligence and report user transaction data under CGI Articles 1649 AC bis to sexies, with declarations covering 2026 transactions due from 2027; a Challenger flag has surfaced an unresolved legal-instrument attribution question, contending 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 serving only as an implementing instrument rather than the primary transposition vehicle -- this has been annotated but not mutated, as the challenging sources are T4-only against a T1-sourced original claim, and awaits verification against the statute text. Separately, the underlying EU instrument, Council Directive (EU) 2023/2226 (DAC8), requires crypto-asset service providers to bring reporting systems, customer due-diligence processes and internal controls into full compliance by 1 July of the applicable year; this claim was downgraded to Probable this cycle for resting solely on a T4 source in a thin-evidence module.

Periodic update · new data 2026-10-18

#### Tax Treatment

The standing tax treatment for French tax residents disposing of digital assets is unchanged this cycle: occasional disposals are taxed at a flat 12.8% income-tax rate plus social levies, calculated on a portfolio-average acquisition-cost basis across the resident&#x27;s holdings. This remains the default rule for ordinary crypto-asset disposals under the Code général des impôts, administered by the DGFiP.

The one movement this cycle is legislative rather than administrative. Amendment I-3898 passed first reading in the National Assembly on 16 October 2026. As drafted, it would specifically treat exchanges of crypto-assets for e-money tokens as a taxable disposal event, and — critically — would calculate the gain or loss on that disposal using a per-asset acquisition-cost basis rather than the portfolio-average method that applies to other disposals under the standing rule. This would be a narrower and more granular calculation method applied specifically to crypto-to-EMT exchanges, diverging from the general portfolio-average approach that continues to apply elsewhere.

The amendment has not been enacted. It has cleared only the first reading stage in the National Assembly; the standing portfolio-average basis continues to apply to all disposals, including crypto-to-EMT exchanges, until and unless the amendment proceeds through further legislative stages and enters into force.

#### Outlook

Whether Amendment I-3898 advances beyond first reading is the defining question for this module going into the next reporting window; the current expectation, carrying a half-year uncertainty band, points to further legislative movement around the first quarter of 2027. Its enactment would be the first France-specific change to crypto tax mechanics since the completion of the MiCA transition, and would introduce a dual-method system — portfolio-average generally, per-asset specifically for crypto-to-EMT exchanges — that operators and tax advisers would need to track separately.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 7 traced claims · Re-verified 2026-11-04

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### France: C7 Cross-Border TransferGreenEnacted in forceModule confidence: Probable&#9662;

France&#x27;s cross-border crypto framework runs on two rails: MiCA&#x27;s EU passporting/reverse-solicitation perimeter and DAC8&#x27;s tax-information-exchange reporting. Non-EU CASPs are prohibited from lawfully providing MiCA-regulated crypto-asset services to, or soliciting, French/EU clients, except under narrow reverse-solicitation, per ESMA&#x27;s public statement on the end of the MiCA transitional period. Conversely, an AMF-authorised CASP benefits from EU-wide passporting rights, allowing cross-border provision of crypto-asset services without separate host-state authorisation; this materiality-4 binding claim was downgraded to Probable this cycle for resting solely on a T4 source in a thin-evidence module. On the tax 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 with an information-exchange agreement -- this claim shares the same legal-instrument attribution question flagged in tax_treatment regarding whether the December 2025 decree or the February 2025 Loi de finances is the true transposition vehicle.

Periodic update · new data 2026-10-05

#### Cross-Border Transfer

CASPs authorised in France are subject to the EU Travel Rule threshold applying to self-hosted-wallet transfers: transfers above euro1,000 require the collection of identity-verification data under the directly-applicable Transfer of Funds Regulation, Regulation (EU) 2023/1113. This threshold is not an FR-specific innovation but a directly-applicable EU rule that binds any CASP holding French authorisation, and it sits alongside the broader MiCA CASP authorisation requirement that now governs market access following the closure of the national PSAN route.

The rule&#x27;s operative effect is to require CASPs to collect and verify counterparty identity information whenever a client initiates or receives a transfer to or from a self-hosted (non-custodial) wallet above the euro1,000 threshold. This is a materially low threshold relative to ordinary retail transaction sizes in crypto-asset markets, meaning the rule captures a substantial share of self-hosted-wallet flows rather than only large transfers. For an operator authorised in France, this represents an ongoing operational compliance obligation layered onto the licensing requirement, rather than a one-off registration step.

No FR-specific enforcement action against a CASP for Travel Rule non-compliance was evidenced this cycle. The rule is described as being in force at the EU level, and applicable to CASPs authorised in France, but the absence of an FR-specific enforcement precedent means the practical rigor of AMF supervision on this specific threshold remains untested in the available sourcing for this cycle.

#### Outlook

The Travel Rule threshold is stable and already in force; it is not a live reform item. What would sharpen this picture is either a named AMF enforcement action testing the euro1,000 threshold, or further AMF/ACPR guidance clarifying practical compliance expectations for CASPs handling high volumes of self-hosted-wallet transfers. Absent such a development, this module is likely to remain a stable compliance backdrop rather than a source of near-term regulatory movement.

Periodic update · new data 2026-08-25

#### Cross-Border Transfer

The EU&#x27;s 20th Russia sanctions package, in force from 23-24 April 2026, extended restrictions on Russia-related crypto activity that are directly applicable in France as an EU Council Regulation amendment to Regulation 269/2014. The package includes measures against the A7A5 stablecoin and RUBx, both associated with Russia-linked payment and settlement infrastructure, and bans all EU support for the digital ruble. Because the instrument is a Council Regulation, France carries no domestic transposition step; the restriction is enforceable immediately upon EU adoption.

For French crypto-asset service providers, this creates a sanctions-compliance layer that sits alongside, rather than replaces, the MiCA authorisation regime: a CASP can be fully MiCA-compliant while still carrying sanctions exposure if it services counterparties linked to the restricted instruments or the digital-ruble ecosystem. This finding is captured here specifically as a disambiguation fact for the crypto monitor&#x27;s cross-border module; the substantive AML/CFT and sanctions-architecture analysis of the same restriction is tracked separately by the financial-integrity monitor&#x27;s D1 domain, and this brief does not duplicate that analysis.

#### Outlook

Further EU sanctions packages extending the list of restricted Russia-linked crypto instruments, or clarifying enforcement expectations for EU-domiciled CASPs with residual exposure to A7A5, RUBx, or digital-ruble-adjacent counterparties, are the markers most likely to affect this module next cycle.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-11-04

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### France: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable&#9662;

AML/CFT supervision of French crypto-asset service providers -- covering KYC/CDD, the travel rule, SAR/STR reporting and sanctions screening -- is exercised jointly by TRACFIN and the ACPR. This module is a subscribed surface consumed from the Financial Integrity Monitor&#x27;s own aml_ctf analysis under fleet subscription doctrine; no original claims are produced within this crypto baseline, and this narrative note documents that boundary rather than a completeness gap.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-11-04

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### France: C9 Commercial Activity unpopulated &#9662;

## Commercial Activity

French crypto-sector commercial activity showed two disclosed funding events this cycle. Morpho Labs is reported to have raised $175.0m in a funding round reported in June 2026; the reporting source did not independently confirm the round stage, participating investors, or a precise transaction date beyond the reported month, and this detail is carried as vendor-sourced rather than primary-filed.

Separately, Spiko is reported to have raised approximately $90m in a Series B round led by New Enterprise Associates, with the raise reported within the thirty days preceding mid-October 2026. As with the Morpho Labs figure, this amount is aggregator-sourced; the precise announcement date was not disclosed in the sourced reporting, though the round stage and lead investor were identified.

Both events reflect continued investor interest in French-domiciled crypto-adjacent businesses during a period in which the underlying licensing perimeter (the MiCA CASP regime) had just completed its transition from the national PSAN registration structure. Neither event carries a confirmed primary-source filing at the time of this cycle&#x27;s research. — Outlook: Given that both figures rest on aggregator or vendor reporting rather than primary filings, the principal open item is independent confirmation — of transaction dates, round stages, and investor composition — should either company or investor issue a primary disclosure. No further commercial events were identified for France this cycle.

No periodic updates recorded in this cycle

Sources and findings (3)
- T4[Morpho Labs](https://www.vcbacked.co/directory/cities/industry/paris-france/cryptocurrency) — Raised $175.0m in a funding round reported June 2026
- T4[Spiko](https://crypto-fundraising.info/) — Raised approximately $90m Series B led by New Enterprise Associates, reported within 30 days preceding mid-October 2026
- T1[Triple-A (PAYTOP SAS)](https://www.amf-france.org/en/warnings/white-lists/casp/paytop-sas-triple) — French Payment Institution licence and MiCA CASP authorisation (A2026-015, 21 May 2026)
