Detailed overview
France: AMF and ACPR MiCA Authorisation Framework
France is a full MiCA jurisdiction. The French framework is based on Regulation 2023/1114 and French implementing provisions in the Monetary and Financial Code.
The French Financial Markets Authority is the main regulator for standard crypto-asset service provider authorisation in France. The French Prudential Supervision and Resolution Authority also has an important statutory role, especially for AML/CFT, sanctions controls and certain regulated financial institutions.
France should not be treated as a continuing DASP registration jurisdiction for new market entry. The former French digital asset service provider regime is now a transitional framework for eligible legacy providers.
Regulator
The main regulator for a standard French crypto-asset service provider application is the AMF.
A standard CASP authorisation application is filed with the AMF. As part of the authorisation process, the AMF obtains a binding ACPR opinion on AML/CFT and restrictive-measures internal-control arrangements and a non-binding ACPR opinion on certain management, continuity, good-repute and competence matters.
The ACPR is also the notification authority for Article 60 notifications by credit institutions, investment service providers other than portfolio management companies and e-money institutions.
The AMF is the notification authority for Article 60 notifications by central securities depositories, market undertakings and AMF-authorised portfolio management companies.
The correct authority must be checked before filing, especially for banks, investment firms, e-money institutions, market operators, portfolio management companies, payment or e-money structures, ARTs and EMTs.
Licensing route
A business that provides crypto-asset services in or from France generally needs MiCA authorisation as a crypto-asset service provider unless it is an eligible financial entity using Article 60 or a duly authorised EU CASP passporting into France.
The relevant crypto-asset services are custody and administration of crypto-assets for clients, operation of a crypto-asset trading platform, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of client orders, placing of crypto-assets, reception and transmission of orders, advice on crypto-assets, portfolio management on crypto-assets and transfer services for clients.
Transfer services are a separate MiCA service and should be included in the service-mapping analysis.
The licence perimeter applies only where the asset is within MiCA. Tokens that qualify as financial instruments, deposits, fund interests, payment instruments, non-MiCA e-money arrangements, insurance products or other regulated products require separate legal analysis.
Article 63 authorisation
A standard unregulated French CASP applicant applies to the AMF for MiCA authorisation.
The AMF now has live CASP application materials. The application package includes the CASP authorisation application form, a management-body form and a DORA cybersecurity self-assessment form.
A credible French application should include a full service map, legal perimeter analysis, business plan, programme of operations, governance package, management fit-and-proper evidence, qualifying-holder information, prudential-safeguard evidence, AML and counter-terrorist-financing framework, sanctions controls, restrictive-measures controls, transaction monitoring, transfer-of-funds controls, DORA and ICT materials, cybersecurity self-assessment, business-continuity plan, outsourcing framework, complaints procedures, conflicts management, custody and client-asset segregation arrangements, client disclosures, pricing and cost disclosures, market-abuse systems where relevant and service-specific policies.
The AMF has warned that initial files are often incomplete. The quality and completeness of the filing are therefore critical to timing.
Article 60 notification
Article 60 is not a general shortcut for unregulated applicants. It is a notification route for specified financial entities and permitted equivalent services.
In France, credit institutions, investment service providers other than portfolio management companies and e-money institutions notify the ACPR.
Central securities depositories, market undertakings and AMF-authorised portfolio management companies notify the AMF.
The AMF and ACPR have a common Article 60 notification form. The notification package should be prepared against MiCA and the applicable EU technical standards.
A regulated entity that wants to provide non-equivalent crypto-asset services may still need full CASP authorisation.
Transitional position
France’s MiCA transition ends on 1 July 2026.
Eligible French digital asset service providers that were registered, licensed or otherwise within the French transitional category before MiCA applied may continue the relevant services in France until 1 July 2026, unless authorisation is granted or refused earlier.
With effect from 1 July 2026, crypto-asset services in France may be provided only by a MiCA-authorised CASP, an eligible Article 60 financial entity whose notification has been deemed complete, or a validly passported EU CASP.
Legacy French DASP status is not MiCA authorisation and should not be marketed as such.
DASP registration or optional DASP authorisation also does not provide an EU passport during the transitional period.
Simplified procedure
France has a limited simplified procedure for certain legacy French providers.
The simplified procedure applies to eligible French-registered or French-licensed DASPs that submit their MiCA authorisation application between 30 December 2024 and 1 July 2026.
The simplified procedure may allow reuse of information and documents already received by the AMF or ACPR where they remain current. It does not remove the need to submit the MiCA Article 62 information package and update changed information.
A legacy provider should not assume that prior DASP registration will convert automatically into MiCA authorisation.
Wind-down
A provider that cannot obtain MiCA authorisation before the end of the French transition should plan an orderly cessation.
The AMF has urged providers that do not intend to continue their activities to implement an orderly cessation with sufficient time. Providers not in a position to continue by 1 July 2026 should limit activity to strictly necessary wind-down operations in advance of the transition deadline.
Wind-down planning should include client communications, closure of onboarding, asset return, complaint handling, custody arrangements, record retention, AML reporting, outsourcing termination and website or marketing updates.
Passporting and register checks
A MiCA-authorised CASP can provide crypto-asset services across the EU through the MiCA passport, subject to the required notification process and authorised service scope.
A French legacy DASP cannot passport on the basis of legacy DASP status.
The AMF publishes a list of providers authorised to provide crypto-asset services in France. AMF and ESMA registers should be checked before relying on a provider’s status, onboarding a counterparty, launching services or publishing any authorisation claim.
Costs
French-authorised CASPs owe an annual AMF contribution.
The current decree fixes the annual CASP contribution at EUR 10,000.
A CASP authorised for custody and administration also owes an additional custody contribution based on assets in custody. The current rate is 0.0094 per mille of assets in custody, with a minimum of EUR 1,500.
Assets in custody are declared by 30 April, and the declaration is accompanied by payment.
A white-paper notification fee of EUR 3,000 may apply where token-offer work is relevant.
These amounts are not the full cost of authorisation. Applicants should also budget for legal, governance, AML, sanctions, DORA, ICT, custody, outsourcing, prudential, management, audit, accounting, complaints, conflicts and service-specific implementation costs.
Fees and contribution rates should be checked before filing because French fee rules may be amended.
Prudential safeguards
A CASP must maintain MiCA prudential safeguards at all times.
The required amount is at least the higher of the applicable permanent minimum capital requirement and one quarter of fixed overheads for the preceding year.
Prudential safeguards may take the form of own funds, an insurance policy, a comparable guarantee or a permitted combination.
The prudential package should be evidenced in the application and maintained after authorisation.
Ongoing obligations
A French CASP must comply with MiCA, French implementation law, AMF requirements, ACPR-related AML/CFT and sanctions expectations where applicable, DORA, transfer-of-funds rules and applicable restrictive-measures obligations.
Core obligations include governance, management suitability, qualifying-holder controls, prudential safeguards, internal controls, risk management, AML and counter-terrorist-financing controls, sanctions screening, transaction monitoring, restrictive-measures controls, ICT and cybersecurity, outsourcing oversight, business continuity, complaints handling, conflicts management, custody safeguards, client-asset and client-fund segregation, recordkeeping, fair and non-misleading client information, cost and fee transparency, market-abuse systems where relevant and service-specific conduct rules.
The AMF applies ESMA staff knowledge and competence guidelines for CASPs. Staff providing information on crypto-assets and staff providing advice should meet the relevant knowledge, competence and training expectations.
Token issuance and white papers
CASP authorisation and token-offer compliance are separate.
A CASP licence does not automatically cover public offers, admission to trading, ART issuance, EMT issuance or white-paper obligations.
Crypto-assets other than ARTs and EMTs, ARTs and EMTs each have different MiCA treatment. ARTs and EMTs may also involve ACPR competence, banking, e-money or payment-services analysis.
A French-facing token offer, listing, white paper, stablecoin structure or marketing campaign should be reviewed separately from CASP authorisation.
Enforcement risk
France is not a light-touch jurisdiction.
The AMF may impose administrative sanctions for MiCA CASP infringements. These may include warning, reprimand, temporary or permanent prohibition of all or part of the services, public statement, injunction to end and not repeat the conduct and financial sanction.
For CASP infringements under MiCA Articles 59, 60, 64 and 65 to 83, the monetary sanction may reach the higher of EUR 5,000,000 or 5 percent of annual turnover for legal persons.
Unauthorised activity and misleading authorisation claims can also create criminal exposure. Breach of the unauthorised-activity prohibition may be punished by two years’ imprisonment and a EUR 30,000 fine. Misleading information or use of a name, corporate name, advertising or other process suggesting MiCA authorisation may be punished by six months’ imprisonment and a EUR 7,500 fine.
The main enforcement risks are operating after 1 July 2026 without MiCA authorisation, complete Article 60 notification or a valid passport; presenting legacy DASP status as MiCA authorisation; using Article 60 without eligibility; providing services outside authorised scope; failing to respond to AMF requests; weak AML or sanctions controls; weak DORA readiness; and misleading marketing or authorisation claims.
Practical assessment
France is suitable for firms that want a MiCA authorisation in a major EU financial market with an experienced crypto-assets regulator and a developed pre-MiCA DASP framework.
It is not suitable for firms looking for a paper registration, indefinite grandfathering, automatic conversion from DASP status, or EU passporting based on legacy French status.
The main execution risks are incorrect service classification, underestimating the ACPR role, treating Article 60 as a general shortcut, relying on transition too late, assuming simplified procedure means reduced substance, filing an incomplete application, failing to prepare AML and sanctions controls, weak DORA or cybersecurity evidence, and marketing legacy status as MiCA authorisation.