France PSAN to MiCA Transition in 2026: The Complete Guide

France was the first major EU country to regulate crypto services

The French Digital Asset Service Provider (PSAN, prestataire de services sur actifs numeriques) regime was created by the 2019 PACTE law. It had two levels:

• Basic registration. Mandatory for custody, crypto-to-fiat or crypto-to-crypto exchange, and trading-platform operation. AML-focused.
• Optional "agrement" (authorisation). A fuller regime with prudential, governance and conduct requirements. Later re-named enhanced DASP registration.

By late 2024, more than 100 PSANs were registered in France. The regime was widely considered the most mature national crypto framework in continental Europe. MiCA superseded it as a standalone regime from 30 December 2024.

The 1 July 2026 hard deadline

Firms that provided crypto-asset services in France in accordance with the PACTE law before MiCA's entry into force may continue until 1 July 2026, or until they are granted or refused a MiCA CASP authorisation. This is the French transitional window and it aligns with the EU-wide 18-month maximum.

On 1 July 2026, providers without a granted MiCA CASP authorisation must cease their activities in France. Failing this, service providers face a criminal liability of two years of imprisonment and a EUR 30,000 fine.

New crypto-service providers cannot use this transitional window. They must apply directly for a MiCA CASP authorisation under AMF supervision, the standard procedure.

The AMF simplified fast-track procedure

The AMF published a dedicated instruction on the simplified MiCA authorisation procedure for existing PSANs. Enhanced DASP holders and basic PSAN registrants benefit from a fast-track review: much of the content that already exists under the PACTE regime is considered compliant with MiCA, subject to minor adjustments.

The AMF guidance sets out which elements of the application file are deemed complete for a PSAN migrating to MiCA:

• Corporate and fit-and-proper documentation. Already submitted to AMF during PSAN registration; reused without re-verification unless changes occurred.
• AML/CFT framework. PSAN-era policies are accepted with targeted updates for Travel Rule (Regulation (EU) 2023/1113) and MiCA-specific obligations.
• Custody policy. PSAN custody documentation reused, supplemented with MiCA Article 75 liability framework.
• Governance and organisational structure. Reused with MiCA-specific updates (four-eyes principle, conflicts, outsourcing register).

What the applicant must add fresh: MiCA-specific conduct rules, market-abuse surveillance for trading platforms, DORA-aligned ICT documentation, suitability and appropriateness for advice and portfolio management services, and the updated business plan under MiCA scope.

Timeline and process

AMF started accepting MiCA CASP applications in early 2025. Timelines in 2026 are as follows:

• Fast-track for enhanced DASP holders. 3 to 5 months end-to-end, using the simplified procedure.
• Fast-track for basic PSAN registrants. 4 to 6 months.
• Standard MiCA procedure for new entrants. 6 to 10 months end-to-end. AMF is among the most thorough EU supervisors for CASP.

France was among the first EU jurisdictions to grant MiCA CASP authorisations. As of 7 October 2026, the ESMA interim MiCA register lists 36 firms with France as their home Member State.

Substance and governance

AMF CASP substance expectations are on par with BaFin and Central Bank of Ireland.

• Head office in France. Effective place of management in France, real office, site visits.
• Two effective managers. At least two dirigeants effectifs resident in France, both subject to individual fit-and-proper assessment.
• Local key function holders. RCCI (compliance and internal control officer), head of risk, head of IT, MLRO - French-resident and full-time.
• Outsourcing. Allowed but AMF checks that critical functions remain overseen in France. DORA-aligned third-party risk management.
• Language. Primarily French, with technical annexes in English accepted by AMF for CASP files (more flexible than for ACPR PI/EMI files).

What PSAN holders must do now

1. File the MiCA application before end-Q1 2026. The AMF has already warned that files arriving in the last two months of the window will struggle to be decided before 1 July 2026.
2. Map the scope delta. Identify which MiCA services the PSAN already performs and which require new documentation.
3. Upgrade conduct documentation. Market-abuse surveillance for trading platforms, suitability for advice, best-execution for order execution.
4. Deploy Travel Rule. Required live at the time of application, not "in progress". EUR 1,000 threshold for self-hosted wallet verification.
5. Confirm capital. Class 1 EUR 50k, Class 2 EUR 125k, Class 3 EUR 150k paid up in cash in a French credit institution.
6. Plan the wind-down if not ready. Migrate client assets to a licensed CASP or passport in from another EU CASP if the deadline is not realistic.

Ship a French MiCA CASP product with Crassula

Crassula provides the white-label software for a French crypto product: crypto accounts with their own deposit addresses, exchange against euro with liquidity from a connected provider, euro accounts, client apps and a back office, all on one ledger with an audit trail. Keys sit in the MPC custody infrastructure you contract, and KYC, Travel Rule messaging and transaction monitoring plug in through connected providers. Market-abuse surveillance and reporting to the AMF stay with your compliance team. Useful for PSAN migrations under the simplified fast-track, for fresh AMF CASP applicants, and for EU banks and PIs using the Article 60 notification to add crypto in France. See the MiCA CASP guide for the full context.

FAQ