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For any firm navigating PSAN MiCA France compliance, the transition from France’s national digital-asset registration regime to the European Union’s Markets in Crypto-Assets framework represents the single most consequential regulatory event since the PACTE law first created the PSAN category. This landing page provides a practitioner-level roadmap covering application documents, governance requirements, capital thresholds, AML/KYC controls, ICT resilience, custody rules and realistic timelines to help compliance officers, founders and in-house counsel convert an existing PSAN registration into a full MiCA PSCA/CASP authorisation before the hard deadline.
That deadline is 1 July 2026. The AMF has publicly reminded all digital-asset service providers that the transitional period allowing them to continue providing services under PSAN registration ends on that date. After 1 July 2026, only firms holding a MiCA PSCA/CASP authorisation or an equivalent licence where payment-service or stablecoin elements are involved may lawfully serve clients in France. The legal basis for this cut-off is Regulation (EU) 2023/1114 (MiCA), Article 143(3). The pages that follow break down exactly what firms must file, with whom, and on what timeline.
Regulation (EU) 2023/1114, commonly known as MiCA, was published in the Official Journal of the European Union on 9 June 2023 and entered into force on 29 June 2023. Titles III and IV (covering asset-referenced tokens and e-money tokens) applied from 30 June 2024, while Title V which governs crypto-asset service providers (CASPs) applied from 30 December 2024. Article 143(3) of MiCA permits Member States to allow existing nationally registered service providers to continue operating under their domestic regime for a transitional period of up to 18 months from that Title V application date. France exercised this option to its maximum extent, setting the backstop at 1 July 2026.
Under the French PACTE law (2019), the AMF administered PSAN registration a national-level process covering a defined set of digital-asset services such as custody, exchange, and platform operation. Registration was mandatory for certain services and optional (as an enhanced “agrément”) for others. The regime was confined to France; it conferred no EU passporting rights, and its prudential, governance and ICT requirements, while meaningful, were lighter than what MiCA now demands.
The PSCA/CASP authorisation under MiCA is a fundamentally different instrument. It covers ten enumerated crypto-asset services, requires full governance and fit-and-proper assessments, imposes detailed prudential capital requirements, mandates ICT risk management aligned with the Digital Operational Resilience Act (DORA), and critically allows the authorised firm to passport its services across the entire EU/EEA. The ACPR plays an active supervisory role where services involve e-money tokens (EMTs) or asset-referenced tokens (ARTs), or where payment-service elements require a dual authorisation.
Firms that were already registered as PSANs and actively providing services before 30 December 2024 may continue to operate under their existing registration until 30 June 2026. On 1 July 2026, the transitional regime expires. Any PSAN that has not by then obtained a full MiCA PSCA/CASP authorisation must cease providing crypto-asset services in France. The ESMA list of Member State grandfathering periods confirms France’s election of the maximum 18-month window. There is no indication that a further extension will be granted.
Every firm currently on the AMF’s PSAN register whether holding a simple registration (mandatory for custody and fiat-to-crypto exchange) or an enhanced agrément must apply for PSCA/CASP authorisation if it wishes to continue operating after 30 June 2026. This includes custodians, exchange platforms, over-the-counter dealers, and advisory firms. New entrants that were not registered as PSANs before 30 December 2024 cannot benefit from the transitional regime and must apply directly for MiCA authorisation. The current register of authorised PSANs is available on the AMF white list published via data.gouv.
The transitional regime is strictly national. A PSAN registration does not authorise cross-border provision of services into other EU Member States, and third-country firms seeking to serve French clients must either establish a legal entity in France and obtain PSCA/CASP authorisation, or rely on the reverse-solicitation exemption (which MiCA construes narrowly). ESMA’s guidance on transitional measures underscores that grandfathering applies only within the notifying Member State.
Where a firm’s services involve the issuance or offering of e-money tokens or asset-referenced tokens, the ACPR has articulated specific expectations, including the potential requirement for a payment-institution or electronic-money-institution licence alongside PSCA authorisation. Firms in this category face dual-authorisation obligations and should engage with both AMF and ACPR early in the process to map the correct application pathway.
The following checklist mirrors the regulatory expectations of the AMF and ACPR for a PSAN MiCA France transition application. It is organised into seven thematic blocks. Each numbered step corresponds to a deliverable that should be regulator-ready before submission.
The table below summarises the principal differences between the outgoing French PSAN regime and the incoming PSCA/CASP authorisation under MiCA. Understanding these distinctions is essential for any firm planning its PSAN MiCA France transition strategy.
| Feature | PSAN (PACTE National Regime) | PSCA/CASP (MiCA Authorisation) |
|---|---|---|
| Legal framework | French PACTE law (2019); AMF General Regulation | Regulation (EU) 2023/1114 (MiCA); directly applicable across the EU |
| Competent authority | AMF (registration and agrément) | AMF for PSCA authorisations; ACPR for EMT/ART prudential supervision |
| Scope of services | Defined set: custody, exchange, platform, advisory | Ten enumerated services under MiCA Title V, including transfer, portfolio management, and advice |
| EU passporting | None national registration only | Full EU/EEA passporting once authorised |
| Transitional status | Grandfathered until 1 July 2026 (if active before 30 Dec 2024) | Full authorisation required from 1 July 2026 onward |
| Governance and fit-and-proper | Basic governance, AML officer, criminal-record checks | Comprehensive fit-and-proper for management body, detailed governance packs, committee structures |
| Capital / prudential requirements | No explicit minimum own-funds (beyond general company law) | Minimum own-funds per service type (€50k–€150k+); ongoing prudential reporting |
| ICT / cybersecurity | General security expectations | Detailed ICT risk management; DORA alignment required |
| Key documentary focus | Registration dossier, AML regime, basic governance | Full programme of operations, prudential evidence, ICT/DORA alignment, AML, custody rules, complaints, marketing compliance |
The AMF opened PSCA authorisation applications in line with MiCA Title V’s application date of 30 December 2024. Industry observers report that realistic processing windows for a complete and well-prepared dossier range from three to six months, though applications involving parallel ACPR review (EMT/ART prudential elements) or complex multi-jurisdictional structures can take longer. The AMF may issue formal questions or requests for supplementary information that stop the assessment clock, effectively extending the timeline. Given the 1 July 2026 hard deadline, firms that have not yet submitted should treat their applications as critically urgent.
AMF application fees for PSCA authorisation are published on the AMF website and are broadly comparable to the fees for enhanced PSAN agrément, adjusted for the expanded scope of review. Beyond regulator fees, firms should budget for:
Illustrative cost bands vary significantly by firm size and service complexity. Industry commentary suggests total one-off transition costs (excluding capital) of €100,000–€500,000 for mid-market operators, though bespoke estimates are essential.
Based on regulator communications and practitioner experience, the most frequent grounds for application delay or refusal include:
Remediation should begin with a targeted gap analysis against each MiCA requirement, followed by prioritised remediation sprints focused on the weakest areas first.
The AMF has intensified its supervisory posture as the transition deadline approaches. Public reminders, withdrawal notices and updates to the AMF blacklist signal a zero-tolerance approach to firms attempting to operate without valid authorisation after 1 July 2026. Under French law, providing digital-asset services without the required authorisation constitutes an offence that can trigger administrative sanctions (fines, injunctions, publication of sanctions decisions) and, in serious cases, criminal prosecution for unauthorised financial-services activity. The EBA has also advised national authorities on actions to take at the end of the transition period, reinforcing the expectation of firm enforcement across Member States.
The AMF retains primary supervisory and sanctioning authority over PSCA-authorised firms. The ACPR exercises concurrent jurisdiction over prudential matters relating to EMT and ART issuers and firms providing payment services. Cross-border enforcement coordination is facilitated through ESMA (for market-conduct matters) and the EBA (for prudential and AML supervision). Referral mechanisms ensure that a deficiency identified by one authority is communicated to the other, and both regulators may impose parallel supervisory measures where necessary.
When the AMF issues a deficiency letter or provisional withdrawal of a PSAN registration, best practice requires immediate containment: the firm should halt onboarding of new clients, issue cessation-of-offering notices to existing clients, and engage with the regulator to clarify the scope of the deficiency. A consumer-remediation plan covering client-asset return, complaint resolution and orderly wind-down where necessary should be prepared and submitted promptly. Firms that respond proactively and transparently are more likely to negotiate a manageable resolution timeline.
The following regulator and institutional sources underpin the guidance on this page. Firms preparing PSAN MiCA France transition applications should consult these primary materials directly:
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