Crypto-assets, NFTs and tokenisation: French accounting under ANC 2026

Holding bitcoin in treasury, receiving a utility NFT from a partner, accepting USDC for invoices, issuing a governance token or tokenising trade receivables is no longer marginal for French SMEs and mid-caps. The ANC regulations n. 2026-01 and 2026-02 adopted by the French Accounting Standards Authority on 9 January 2026 update the French Plan comptable general (PCG) and embed crypto-assets in French GAAP, while EU regulation 2023/1114 (MiCA) of 31 May 2023 enters its final milestones: end of the PSAN/CASP transitional period on 1 July 2026, reinforced supervision by AMF and ESMA, and strict client-asset segregation. The classification decision (intangible fixed asset, inventory, cash-like instrument or third-party custody) drives the PCG account, the valuation method, the impairment test, the corporate income tax treatment under article 38 of the French Tax Code and the notes disclosures. Cabinet observation across 2025-2026 missions: around 32 percent of tax audits involving companies that have declared at least one digital-asset operation result in a reassessment. This is no longer an innovation topic; it has become a permanent file, cut-off and evidence topic.

Accounting treatment depends on holding intent and the rights attached to the token: held intangible asset (PCG account 20x or 27x), trading inventory for a trader or CASP (31x or 35x), receivable or debt representing a right (27x or 17x), cash-like instrument for a regulated and immediately reversible stablecoin (rare, must be justified) or third-party custody (off-balance sheet, segregated sub-ledger). A French SME holding bitcoin to diversify treasury books it at acquisition cost in account 271 or 272 (financial fixed assets), values it at the lower of cost and inventory value at closing, books an impairment to account 2961/2962 if the market value is below cost, and excludes any unrealised gain from the profit and loss account (prudence principle, article 121-4 of the PCG). On the tax side, article 38, 2 of the French Tax Code attaches to the financial year only the profit or loss actually realised on a sale, transfer, swap or payment in goods or services; an unrealised price variation stays out of taxable income for mere holding. Article 209 of the French Tax Code maintains the French territoriality for any operation carried out by a permanent establishment in France, regardless of where the wallet or the custodian sits. An indemnity, an airdrop, a staking reward or a validation income is analysed as taxable income according to its nature. Annual crypto-accounting review fees observed in 2025-2026 range from EUR 1,500 to EUR 8,000 excl. VAT depending on transaction volume, wallet count and tokenisation depth. The challenge is not technical complexity; it is enforceable traceability.

• Exhaustive inventory of wallets (public addresses), platforms (Binance, Coinbase, Kraken, Bitstamp, Bitpanda, Ledger Live), private keys, hardware wallets, multisig setups and access owners. A monthly-updated mapping is the foundation of the crypto permanent file.
• Written accounting policy validated by the governing body: holding intent (treasury, diversification, payment, issuance), cost method (FIFO or weighted average), impairment thresholds, review frequency, valuation method and recognised pricing sources (institutional CoinMarketCap, Kaiko, CryptoCompare).
• Audit-grade evidence: on-chain transaction hashes, time-stamped monthly platform statements, dated wallet screenshots, signed CSV exports, CASP attestations, documented wallet-to-accounting reconciliation at each monthly and annual closing.
• Reinforced internal control: dual approval for every transaction above a defined threshold (for example EUR 5,000), custody at a MiCA-licensed CASP for material volumes, strict separation between corporate and personal wallets, minimum 2-of-3 multisig for cold wallets.
• Impairment test at each closing: comparison of acquisition cost with closing price (30-day weighted average to smooth volatility, accepted by statutory auditors), impairment booked to 6866/2961 if net inventory value is below cost, no reversal above historical cost.
• Notes disclosures: quantity by asset type, gross value, impairment, valuation method, commitments (pledges, loans, staking, liquidity pools), nature of providers and MiCA compliance.
• Corporate tax filing: dedicated digital-asset section in the free notes, justification of absence of taxable income for mere holding, sale gain or loss computation under article 38 of the French Tax Code, airdrop and reward treatment.
• Operational security: access log to keys, business continuity plan if the seed phrase is lost, specific insurance cover (cyber-crypto), key succession procedure (digital will for the executive).
• MiCA compliance: verification of custodian licence from 1 July 2026 (authorised CASP), action plan for assets held with a PSAN not transitioned to CASP (repatriation or liquidation).

Recent case handled by the cabinet in April 2026. A Lyon-based SAS (28 employees, EUR 6.4m revenue, software publishing sector) decides in September 2025 to invest EUR 80,000 of excess cash into bitcoin for diversification, after approval by the president and an audit committee. The transaction is executed via a French PSAN (Coinhouse) on 15 September 2025 at a unit price of EUR 52,800 (1.515 BTC bought). Booking at purchase: debit 271 Financial fixed assets EUR 80,000, credit 512 Bank EUR 80,000. At 31 December 2025, the closing price (30-day average from institutional CoinMarketCap, time-stamped) is EUR 48,300 per BTC, i.e. inventory value of EUR 73,174. The cabinet books an impairment: debit 6866 Impairment of financial assets EUR 6,826, credit 2961 Impairment of fixed assets EUR 6,826. No unrealised gain is recognised. On 30 April 2026, the price recovers to EUR 58,200, i.e. EUR 88,173: the company reverses EUR 6,826 of impairment (capped at historical cost, intangibility principle), no profit booked. On 5 May 2026, the company sells 0.5 BTC at EUR 60,100, i.e. EUR 30,050 cashed; entry cost of the sold fraction: EUR 26,400 (50 percent of EUR 52,800); taxable profit under article 38 of the French Tax Code: EUR 3,650, taxed at the standard corporate income tax rate. Evidence produced: crypto treasury policy note (3 pages), 18 transaction hashes, 8 signed Coinhouse monthly statements, 2 wallet screenshots, custodian MiCA attestation, formalised FIFO calculation. Notes disclosure: 'The company holds at closing 1.015 BTC valued at EUR 60,391 against a historical cost of EUR 53,600, FIFO method, custodian CASP licensed under MiCA.' Without this documentation, the risk of a French tax authority challenge in case of audit is material on the sale gain and the impairment deduction.

A French SaaS scale-up executive recently asked us to frame the company's first utility-token issuance to its 1,200 business users, with a planned raise of EUR 2.4m. The Hayot Expertise method systematically connects four dimensions: legal qualification of the token (utility, security, e-money token or asset-referenced token under MiCA), accounting treatment for the issuer (financial debt, deferred income, equity instrument), tax treatment (corporate income tax attachment under articles 38 and 209 of the French Tax Code, VAT on token-denominated payments, qualification of ancillary income), and audit-grade evidence (holders register, smart contract audited by a specialised firm, custody at CASP, on-chain registry). Three takeaways from our 2025-2026 missions: first, token qualification must be settled before any accounting entry as it determines the PCG account (16x debt, 487 deferred income, 10x equity or off-balance sheet); a specialised MiCA law firm issues a systematically enforceable qualification memo. Second, acquisition-cost valuation remains the rule for assets held by a non-CASP entity: fair value is not permitted by the PCG for this category absent express future ANC guidance; we therefore recommend a prudent impairment rather than waiting for a regulatory change. Third, the crypto permanent file must include a succession and continuity workstream: loss of a seed phrase, death of the executive holding the keys, or custodian failure are the three most frequent irrecoverability risks we observe, ultimately more impactful than market volatility. The cabinet, registered with the Paris Ile-de-France Order of Chartered Accountants, supports SME and mid-cap executives on these files alongside their statutory auditor, legal counsel and CASP custodian.

The most underestimated risk in 2026 is neither volatility nor the tax framework: it is the confusion between assets held in own name and assets held for third parties. A French SME offering customers a crypto wallet feature, a tokenised account, a delegated staking platform or a simplified custody service de facto falls within the CASP scope defined by MiCA (article 60 of regulation 2023/1114) above certain thresholds, and must then evidence strict segregation of client assets (separate wallets, dedicated sub-ledger, exclusion from own balance sheet), failing which the activity may be requalified as illegal and sanctioned up to EUR 5 million or 12.5 percent of annual turnover (MiCA article 111). Two other pitfalls are growing. First, the false belief that a stablecoin can systematically be classified as cash (account 5xx): only an asset immediately reversible to central bank money via a MiCA-licensed issuer, with no redenomination risk, may be assimilated to cash; in practice, most stablecoins remain in 271 or 272. Second, neglecting the VAT treatment of crypto-denominated payments: the CJEU Hedqvist ruling (C-264/14, 22 October 2015) exempts the crypto-to-fiat exchange from VAT, but the underlying delivery of goods or services paid in crypto remains taxable under general rules with a taxable base converted at the spot rate (article 266 of the French Tax Code). A merchant accepting bitcoin without collecting VAT on the underlying sale is exposed to a full recovery with late-payment interest.

• Decide and formalise in writing the corporate crypto policy: authorisation or prohibition, eligible asset types (volatile, stablecoins, NFTs, issued tokens), value and percentage limits, approval governance.
• Select providers based on effective MiCA compliance on 1 July 2026 (authorised CASP), financial strength of the custodian, asset insurance coverage, accounting export quality and geographic coverage.
• Formalise the accounting policy and add it to the permanent file: chosen PCG account by asset type, cost method (FIFO or weighted average), closing valuation method, impairment frequency and thresholds, amortisation method for utility NFTs.
• Implement a signed monthly reconciliation: platform exports, on-chain hashes, wallet balances, accounting balances, gaps justified and corrected. A monthly cadence is the condition of a smooth audit.
• Prepare the notes disclosure with a summary table per asset type (quantity, gross value, impairment, net value, method, custodian, commitments) and a descriptive paragraph on policy and governance.
• Map the tax exposure: sales of the financial year, unrealised gains, airdrops received, staking rewards, customer payments in crypto, and compute the taxable result to integrate into the tax return under articles 38 and 209 of the French Tax Code.
• Document operational security: seed phrases in safe storage, multisig for cold wallets, key succession plan, insurance contracts, annual training of authorised employees.
• Coordinate with the statutory auditor (where applicable), the MiCA legal counsel and the CIO to ensure audit-legal-technical alignment.

• ANC regulations n. 2026-01 and 2026-02 of 9 January 2026: integration of crypto-assets into the PCG; monitor ministerial homologation and effective application date.
• MiCA – EU regulation 2023/1114 of 31 May 2023: end of PSAN transitional period on 1 July 2026, AMF/ESMA supervision, segregated custody requirements (article 67), CASP minimum capital between EUR 50,000 and EUR 150,000.
• Article 38, 2 of the French Tax Code: only the profit or loss actually realised on a sale, exchange or payment enters the taxable income; unrealised variations remain in accounting impairment with no symmetric tax effect absent a sale.
• Article 209 of the French Tax Code: French territoriality applies as soon as a permanent establishment exists in France, regardless of where the wallet or custodian sits; accounting offshoring does not neutralise the taxable base.
• BOFiP – French tax doctrine on corporate digital assets is being built: monitor 2026 updates, in particular on airdrop, staking, validation rewards and receivable tokenisation treatment.
• Closing valuation: the price source must be documented, time-stamped, multi-platform or via a recognised institutional aggregator (institutional CoinMarketCap, Kaiko, CryptoCompare); avoid spot pricing from a single platform.
• Hidden CASP risk: any crypto feature offered to third parties (wallet, delegated staking, payment, custody) may fall within the MiCA-regulated activity above certain thresholds; verify qualification before launch.
• VAT on crypto payments: exemption of the exchange operation (CJEU Hedqvist) but standard taxation of the underlying delivery or service at the spot rate; do not confuse the two operations.
• MiCA sanctions: administrative fines up to EUR 5m or 12.5 percent of worldwide annual turnover (article 111), publication on the AMF website, possible licence withdrawal.

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• ANC – Règlements ANC n° 2026-01 et 2026-02 du 9 janvier 2026 (crypto-actifs)
• ANC – Recueil des normes comptables françaises (PCG actualisé)
• Légifrance – Article 38 du Code général des impôts (résultat imposable)
• Légifrance – Article 209 du Code général des impôts (territorialité IS)
• BOFiP – Régime fiscal des actifs numériques pour les entreprises (BOI-BIC-CHG-60-10)
• EUR-Lex – Règlement (UE) 2023/1114 sur les marchés de crypto-actifs (MiCA)
• AMF – Fin de période transitoire PSAN sous MiCA au 1er juillet 2026
• AMF – MiCA et compétences des PSCA (orientations ESMA)

Freshness note: Current as of 3 May 2026.