Stablecoin issuer / redeemer in France
Issues a fiat-pegged stablecoin to the public, operates redemption, and holds reserves backing the float.
Stablecoin issuer is conditionally permitted in France with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- Must hold either an e-money institution (EMI) license or credit institution authorization from ACPR to issue e-money tokens (EMTs) under MiCA.
- CASP authorization under MiCA via AMF also required for related services (e.g., custody, exchange) — minimum capital applicable (€150k for exchange, €50k for custody).
- Full KYC/CDD on all holders: collect, verify, and store identity documents (two forms of ID); third-party onboarding permitted.
- Enhanced Due Diligence (EDD) required for high-risk cases — PEPs, transactions over €1,000 to self-hosted wallets, cross-border activity.
- Ongoing transaction monitoring, KYB for corporate clients (beneficial ownership verification), and ML/FT risk assessment systems.
- FATF Travel Rule compliance (MiCA requirement for CASPs)
- Suspicious transaction reports (STRs) to TRACFIN.
- Managers and beneficial owners verified during AMF/ACPR registration.
- DAC8 reporting obligations (effective Jan 1, 2026) — report user crypto transactions to tax authorities.
Key Restrictions
- Stablecoin issuer must be a legal entity established in the EU (likely France) authorized as an EMI or credit institution by ACPR.
- Reserves backing the stablecoin float must be segregated, composed of highly liquid low-risk assets (e.g., cash, short-term government bonds), and subject to mandatory audit under MiCA.
- Holders must be granted unconditional redemption rights at par value — redeemable at any time and free of charge (MiCA Article 39).
- Foreign-issued (non-EU-authorised) stablecoins may not be offered to the French/EU public unless the issuer holds a comparable EU authorization and the stablecoin is classified under MiCA.
- Transition from PSAN/DASP regime to full MiCA CASP + EMI/credit institution licensing required — existing PSANs had to apply by June 30, 2025.
- Minimum capital requirements under MiCA: €125k–€350k for CASP activities; EMI licensing also requires own funds (€350k minimum for EMI under EMD2 / MiCA).
Key Risks
- Dual-regulator burden: ACPR (prudential/EMI supervision) + AMF (CASP/crypto supervision) creates overlapping compliance obligations.
- Short transition window for legacy PSANs creates regulatory bottleneck risk.
- Complexity of reserve composition and segregation compliance under MiCA's strict asset-referencing rules.
- Foreign stablecoins (e.g., USDT) face uncertain local-law status if not MiCA-compliant — enforcement risk for distribution.
- Tax exposure: 30% flat tax (PFU) applies to crypto capital gains for individual holders, creating reporting friction.
- DAC8 reporting from 2026 adds data-sharing obligations with tax authorities — privacy and operational risks.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
The AMF is the French competent authority for MiCA CASP authorisation, and France is the second-largest EU home of authorised CASPs (AMF, 6 July 2026). Circle Internet Financial Europe SAS is listed by ESMA as an AMF-authorised CASP from 23 April 2026 and, separately, as an ACPR-supervised e-money institution issuing the EURC and USDC e-money tokens since 1 July 2024.
The ACPR (Autorité de contrôle prudentiel et de résolution) is the French prudential and AML/CFT supervisor for banks and insurers, applying Monetary and Financial Code articles L. 561-2 ff. and R. 561-1 ff.; under the PACTE regime it gave its AML/CFT opinion on each PSAN before AMF registration.
MiCA Regulation (EU) (2023) — CASP authorization, comprehensive crypto regulation
The loi PACTE of 22 May 2019 created the French regime for initial coin offerings and digital-asset service providers (PSAN). The AMF states that this national regime is to disappear under MiCA, and the PSAN transitional period ended on 1 July 2026.
France applied the full 18-month MiCA transitional period: PSANs registered or licensed under French law could keep serving clients until 1 July 2026. Since 2 July 2026 only crypto-asset service providers (PSCA) authorised under MiCA may provide crypto-asset services in France; the AMF reported 31 French authorisations on 6 July 2026.
Custody and administration of crypto-assets on behalf of clients is a MiCA Class 2 service requiring minimum capital of €125,000 (Regulation (EU) 2023/1114, Annex IV). In France the AMF authorises CASPs offering it; the ESMA interim register listed 36 AMF-authorised French entries on 14 October 2026.
Operating a trading platform for crypto-assets is a MiCA Class 3 service requiring minimum capital of €150,000 (Regulation (EU) 2023/1114, Annex IV). In France it requires AMF authorisation as a PSCA, mandatory for all providers since the PSAN transition ended on 1 July 2026.
The AMF is the French competent authority that authorises and supervises crypto-asset service providers (PSCA) under MiCA, replacing the PSAN registration and licensing regime of the loi PACTE; it also oversees offers of crypto-assets other than asset-referenced and e-money tokens, whose issuers must be authorised by the ACPR.
The ACPR is the French authority for stablecoin issuers under MiCA: an e-money token issuer must be authorised as a credit institution or electronic money institution and notify the ACPR of its intention to issue and of its white paper. On 14 October 2026 the ESMA register listed 8 French EMT white papers from 6 ACPR-supervised issuers, including Circle Internet Financial Europe SAS, Société Générale – Forge and SALVUS (schuman.io).
Banque de France Governor Emmanuel Moulin told the ACPR-AMF Fintech Forum on 2 October 2026 that a targeted revision of MiCA could clarify the legal treatment of tokenised deposits and of stablecoins, including non-euro stablecoins used for everyday payments and multi-issuer models; this is a policy position, not a rule.
Tracfin, the French financial intelligence unit under the Ministry of the Economy, receives AML/CFT suspicious-transaction declarations; the ACPR and Tracfin have issued joint guidelines on vigilance obligations and on declarations and information to Tracfin.
France has replaced the PSAN regime with MiCA authorisation: the AMF stated on 6 July 2026 that the transition from the loi PACTE regime ended on 2 July 2026, that France had authorised 31 crypto-asset service providers and that 283 were authorised across the EU. The ESMA interim register listed 36 AMF-authorised French entries on 14 October 2026.
France's transposition of DAC8 (Council Directive (EU) 2023/2226), including the instrument, its date and the reporting duties of crypto-asset service providers, has no French primary source reachable on 14 October 2026.
AML/CFT for CASPs (since December 30, 2024): Mandates KYC, transaction monitoring, and sanctions compliance.
The loi PACTE of 22 May 2019 created the French PSAN regime, which required at a minimum an AML/CFT framework; the ACPR gave its AML/CFT opinion on each digital-asset service provider before AMF registration because these providers present high money-laundering risks.
The ACPR lists Directive (EU) 2015/849 as amended by Directive (EU) 2018/843 (the fifth AML directive) among the EU AML/CFT texts in force in France, alongside Monetary and Financial Code articles L. 561-2 ff.; the AMLR (2024/1624) applies from 10 July 2027 and AMLD6 (2024/1640) must be transposed by that date.
MiCA sets CASP minimum capital at €50,000 (Class 1), €125,000 (Class 2, including custody and exchange) or €150,000 (Class 3, trading platforms) under Annex IV of Regulation (EU) 2023/1114. French PSANs had until 1 July 2026 to obtain AMF authorisation, and transfers of crypto-assets follow Regulation (EU) 2023/1113, which the ACPR lists as in force.
EU AML Regulation (AMLR) and Sixth AML Directive (AMLD6): Standardizes KYC as ongoing, risk-based processes across EU, explicitly including CASPs/VASPs; aligns with AMLA for cross-border supervision.
2024 CMF Update: Adds MiCA-aligned requirements for DASPs.
Collect, verify, and store identity documents (e.g., two forms of ID); use third parties permitted.
Under Regulation (EU) 2023/1113, which the ACPR lists among AML/CFT texts in force in France, a CASP handling a transfer exceeding €1,000 to or from a self-hosted address must verify whether that address is owned or controlled by its client; enhanced vigilance for politically exposed persons is covered by ACPR guidelines under Monetary and Financial Code articles L. 561-2 ff.
Ongoing transaction monitoring, KYB for corporate clients (beneficial ownership), and ML/FT risk assessment systems.
Since the PSAN regime ended on 1 July 2026, management and shareholder checks run through AMF authorisation under MiCA: the AMF must refuse a CASP whose management body members lack sufficiently good repute and competence (Art 68(1)) or whose qualifying shareholders are unsuitable (Regulation (EU) 2023/1114, Art 63(10)). Under the former PSAN regime the ACPR gave an AML/CFT opinion before AMF registration.
Evidence fact fr.tax not found (may have been renamed).
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — issuing a fiat-pegged stablecoin in France requires dual authorization as an e-money institution (or credit institution) with ACPR plus a MiCA CASP license with AMF, compliance with strict reserve segregation, mandatory audit, par-value redemption rights, and full AML/CTF obligations including Travel Rule and DAC8 reporting.
Questions this verdict aims to answer
- What e-money or banking license is required to issue?
- What reserve composition, segregation, and audit rules apply?
- What redemption rights must be granted to holders?
- Are foreign-issued stablecoins permitted for use locally?