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).
AMF — CASP authorization — most experienced EU NCA for crypto. Circle chose France for EU MiCA authorization.
MiCA Regulation (EU) (2023) — CASP authorization, comprehensive crypto regulation
PACTE Law (Loi PACTE) (2019) — Prior PSAN/DASP regime — EU's most mature pre-MiCA framework, replaced by MiCA
VASP: CASP authorization under MiCA via AMF. SHORT 6-month transition (existing PSANs had to apply by June 30, 2025). 3-6 months (AMF is experienced). France positioning as EU crypto hub.
CUSTODY: CASP authorization — custody is a licensed MiCA activity (EUR 50,000 minimum capital)
EXCHANGE: CASP authorization — EUR 150,000 minimum capital for trading platforms
Autorité des Marchés Financiers (AMF): Primary authority for registering/licensing Crypto-Asset Service Providers (CASPs, formerly Digital Asset Service Providers or DASPs), supervising crypto offerings (except stablecoins), and enforcing investor protection, AML, and financial regulations.
Autorité de Contrôle Prudentiel et de Résolution (ACPR): Oversees prudential supervision, AML compliance (with AMF), stablecoin issuers (e.g., authorizing Circle France, Schuman Financial, Société Générale Forge), and certain DLT infrastructures.
Banque de France (BdF): Monitors stablecoins used as payment means and specific DLT setups; coordinates with AMF/ACPR.
TRACFIN: Handles suspicious transaction reports for AML/CFT.
French adaptations to MiCA: Order (October 15, 2024), Decree (February 21, 2025), Law (April 30, 2025); replaced DASP regime with CASP licensing, integrated electronic money tokens (EMTs), and aligned with EU standards. Over 100 DASPs registered previously.
DAC8 implementation (Finance Bill 2025, effective January 1, 2026): Requires CASPs and tied providers to report user crypto transactions to tax authorities.
AML/CFT for CASPs (since December 30, 2024): Mandates KYC, transaction monitoring, and sanctions compliance.
PACTE Law (Loi PACTE, 2019): Introduced mandatory registration for DASPs (e.g., crypto exchanges, custodians, wallet services, crypto-to-crypto platforms) and imposed AML standards.
EU Fifth AML Directive (5AMLD): Implemented in France in January 2020, requiring AML/CFT policies, CDD, and registration for all crypto firms serving French clients.
Markets in Crypto-Assets Regulation (MiCA): Enhances transparency, security, and AML for crypto providers; DASPs must transition to CASP licensing with minimum capital (€125,000–€350,000) and FATF Travel Rule compliance.
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.
Enhanced Due Diligence (EDD): For high-risk cases like PEPs, transactions over €1,000 to self-hosted wallets, or cross-border activities.
Ongoing transaction monitoring, KYB for corporate clients (beneficial ownership), and ML/FT risk assessment systems.
Managers and beneficial owners verified during 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?