DAC 8 crypto-assets 2026: what platforms, holdings and corporate holders must report in France
DAC 8 takes effect on 1 January 2026 in France: a complete guide for CASPs, holdings and crypto-holding companies. Legal framework, MiCA interaction, sanctions and roadmap to the 2027 filing.
Expert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
Updated on 18 September 2025.
1 January 2026 marked the entry into force of France's transposition of EU Directive 2023/2226 (DAC 8) — a paradigm shift for the French crypto market. From now on, Crypto-Asset Service Providers (CASPs) established in or operating in France must identify, collect and annually transmit to the DGFiP the full record of crypto operations carried out by their EU-resident users.
Codified in Articles 1649 AC bis through 1649 AC sexies of the French Tax Code (CGI) by Decrees no. 2025-1276 and 2025-1277 of 19 December 2025, DAC 8 is part of a global convergence (OECD's CARF) that now makes it almost impossible to hide a crypto portfolio. For CASPs, it is a major operational project; for corporate holders and exposed holdings, it is an additional layer of transparency to anticipate.
This pillar guide sets out the exact scope, the interplay with MiCA (and the end of the transitional PSAN regime on 1 July 2026), the reporting calendar, the sanctions and the operational checklist for the first filing in 2027.
- Legal framework: EU Directive 2023/2226 (DAC 8), transposed by Decrees no. 2025-1276 and 2025-1277 of 19 December 2025, codified in CGI Articles 1649 AC bis to sexies.
- Scope: any MiCA-defined CASP operating in France or with EU-resident users.
- Effective date: operations from 1 January 2026 — first return due before 15 June 2027.
- MiCA interplay: the PSAN transitional regime ends on 1 July 2026. No MiCA CASP license = exit from the French market.
- Penalties: €200 per missing report per user, €1,500 per missing KYC, possible withdrawal of MiCA authorization.
The European framework
EU Directive 2023/2226 of 17 October 2023 (DAC 8) amends Directive 2011/16/EU on administrative cooperation in tax matters. It extends the automatic exchange of information to crypto-asset transactions, aligning the EU with the OECD's Crypto-Asset Reporting Framework (CARF) published on 8 June 2023.
The political objective: end the asymmetry between traditional financial assets (already covered by CRS and FATCA) and crypto-assets, where national tax authorities lost visibility as soon as users dealt with non-resident actors.
French transposition
France transposed DAC 8 through two decrees published in the JORF on 24 December 2025:
- Decree no. 2025-1276 — reporting and due diligence obligations on CASPs (CGI Articles 1649 AC bis to sexies).
- Decree no. 2025-1277 — update of the Common Reporting Standard to incorporate DAC 8 changes.
The obligations apply to operations from 1 January 2026 onwards, with the first CASP return to the DGFiP due before 15 June 2027.
Who is a CASP under MiCA?
The term CASP (Crypto-Asset Service Provider) from EU Regulation MiCA (2023/1114) covers any entity providing on a professional basis one or more of:
- custody and administration of crypto-assets on behalf of third parties;
- operation of a crypto-asset trading platform;
- exchange of crypto-assets for funds or other crypto-assets;
- order execution, placement, reception and transmission of orders;
- investment advice and portfolio management on crypto-assets;
- transfer services.
Our expert view
The classic trap: assuming DAC 8 only concerns the big exchanges (Binance, Coinbase, Kraken). False. A niche French CASP — a real-estate tokenization boutique, an NFT marketplace, a family-office custodian — is fully within scope as soon as it provides a remunerated service on crypto-assets to an EU resident. And the PSAN registration obtained under the PACTE law is no longer enough: a switch to a MiCA CASP authorization before 1 July 2026 is mandatory, otherwise the activity becomes illegal AND the DAC 8 obligations remain without the authorization to fulfil them. We are this year supporting several historical PSAN platforms through this dual transition — the runway is tight.
For each reportable user, the CASP must annually transmit to the DGFiP:
| Category | Data |
|---|---|
| Individual user identification | First and last name, date and place of birth, main address, country of tax residence, TIN (French tax reference or foreign equivalent) |
| Legal entity identification | Name, registered office, country of tax residence, TIN, indication whether it is a passive non-financial entity with controlling person (look-through) |
| Transaction data | For each crypto-asset: operation type (buy, sell, swap, transfer), date, gross EUR amount (and crypto amount), counterparty, fees |
| Balances (where applicable) | Balance per crypto-asset as of 31 December |
| Self-certification | Signed declaration from the user attesting residence and TIN |
Reportable operations include: sales, crypto-to-crypto swaps, wallet-to-wallet transfers, staking, airdrops, payment of salaries/invoices in crypto as long as they flow through the CASP.
Three frameworks intersect in 2026:
| Framework | Nature | Application |
|---|---|---|
| MiCA (EU Reg 2023/1114) | Prudential — authorization | CASP applicable since 30/12/2024; PSAN transition ends 1 July 2026 |
| DAC 8 (EU Dir 2023/2226) | Tax — EU reporting | Operations from 01/01/2026; first return before 15/06/2027 |
| OECD CARF | Tax — global exchange | First exchange between adhering jurisdictions expected in 2027 |
Operational impact: a French CASP has 7 weeks (between 13 May 2026 and 1 July 2026) to complete its PSAN → MiCA CASP transition if not already done. Beyond that, the activity becomes illegal and the AMF can order immediate cessation, with an administrative fine.
Profile: Paris-based NFT marketplace, PSAN-registered since 2023, 1,200 active users (80% French residents, 15% EU, 5% non-EU), €4M in commissions in 2026.
Estimated annual compliance cost
| Item | Annual cost |
|---|---|
| PSAN → MiCA CASP transition (prudential audit, capital, governance) | €80,000 – €150,000 |
| KYC upgrade for DAC 8 (self-certification, TIN check, look-through) | €40,000 – €80,000 |
| DAC 8 reporting platform (CRS-rev XML, aggregation, controls) | €25,000 – €60,000 |
| DAC 8 officer and ongoing training | €35,000 – €60,000 |
| Total | €180,000 – €350,000 |
For a €4M-revenue marketplace, compliance represents 5–9% of revenue. Significant but unavoidable.
Financial penalties (CGI Articles 1736 and 1729)
| Breach | Penalty |
|---|---|
| Total failure to file annual return | €200 per missing user, capped per period |
| Missing reinforced KYC due diligence | €1,500 per user, capped |
| False or incomplete data | Proportional fine + interest |
| Repeated or serious breach | Possible withdrawal of MiCA authorization by AMF |
The underestimated risk
The most costly risk is not the DGFiP fine — it is the AMF's withdrawal of MiCA authorization for repeated DAC 8 breaches. A CASP that loses MiCA authorization loses the right to operate across the whole EU (reverse passporting). For a French tech platform aiming at the European market, this is commercial death. DAC 8 compliance is therefore not negotiable on cost grounds — it is existential.
- Eligibility diagnosis: is my company a CASP under MiCA? (test: remunerated service on crypto-asset to a third party)
- MiCA status: am I a PSAN or already a MiCA CASP? If only PSAN, switch plan before 1 July 2026.
- Reinforced KYC: have all users signed a self-certification with TIN? If not, immediate collection campaign.
- Technical infrastructure: do I have a tool able to export my 2026 operations in CRS-rev XML before 15 June 2027?
- DAC 8 officer: who is appointed internally? What process for a DGFiP request?
- CARF coordination: for non-EU users, check whether the jurisdiction adheres to OECD CARF.
- 1 July 2026: end of the PSAN transitional regime — mandatory switch to MiCA CASP to continue operating.
- 31 December 2026: close of the first DAC 8 reporting year.
- Before 15 June 2027: first DPI annual return of CASPs to the DGFiP.
- Summer 2027: pre-fill of individual income tax returns with crypto data transmitted by CASPs.
- DAC 7 articulation: if the platform combines classic marketplace + crypto (NFT), dual reporting obligation (DAC 7 + DAC 8). See our DAC 7 guide.
- Tax audits: the DGFiP will systematically cross-check CASP returns against individual income tax returns and corporate tax filings. Omissions will be detected automatically.
DAC 8 puts an end to the French crypto grey zone. For CASPs, it is a prudential AND tax obligation, doubly constraining. For corporate holders and exposed holdings, it is new visibility for the DGFiP on their crypto positions. The operational window — MiCA switch + reinforced KYC + DAC 8 infrastructure — is closing fast.
Our firm supports CASPs, patrimonial holdings and corporate holders on MiCA/DAC 8 compliance audits, reinforced KYC implementation and preparation of the first 2027 return. Contact our experts.
Frequently asked questions
My company holds USDC in its treasury: does DAC 8 apply to me directly?
No, not as a holder. DAC 8 targets crypto-asset service providers (CASPs) that carry out transactions on behalf of third parties. If your company holds USDC in a self-hosted wallet or through a CASP, it is the CASP that will report your transactions to the DGFiP, not you. However, your company is still required to account for these assets (ANC Regulation 2020-05) and to report any capital gains (Article 150 VH bis of the French Tax Code or corporate tax, depending on the activity). DGFiP audits will cross-check your returns against the data transmitted by the CASP.
What is the difference between MiCA registration (CASP) and the DAC 8 obligation?
MiCA (EU Regulation 2023/1114) is the prudential framework: to provide crypto-asset services in France after 1 July 2026, a provider must be authorised as a CASP by the AMF. DAC 8 (EU Directive 2023/2226, transposed by Decree No. 2025-1276 of 19 December 2025) is the tax obligation: that same CASP must report annually to the DGFiP the transactions of its EU-resident users. The two regimes are independent but linked: no MiCA registration = no lawful activity; MiCA activity = automatic DAC 8 obligation.
What are the first DAC 8 reporting deadlines?
Article 1649 AC bis to Article 1649 AC sexies of the French Tax Code apply to transactions carried out from 1 January 2026. The first annual report by CASPs to the DGFiP will therefore cover the year 2026 and will be due before 15 June 2027, via the dedicated online service on impots.gouv.fr. The technical format will be published during the second half of 2026 (XML schema aligned with the revised CRS). For individual and corporate users, the impact will be felt from summer 2027, with tax returns pre-filled with the crypto-asset income transmitted by the CASP, similar to the pre-filling of dividends.
My company uses a CASP based in the United Arab Emirates: will the DGFiP still receive my data?
It depends on whether an automatic exchange agreement exists between the UAE and France. On 21 July 2025, the UAE signed the multilateral competent authority agreement under the OECD Crypto-Asset Reporting Framework (CARF), which converges with DAC 8. According to the UAE Ministry of Finance, the framework applies there from 1 January 2027, with a first automatic exchange in 2028 covering the year 2027: transactions carried out in 2026 are therefore not covered by this exchange. For later years, if the exchange is activated between the two countries, your data will be transmitted to the DGFiP. In any event, your company reports its own results and, under Article 1649 bis C of the French Tax Code, must report at the same time the details of the crypto-asset portfolios opened, held, used or closed with a provider established abroad. Failure to do so is subject to a fine of €750 per portfolio not declared, raised to €1,500 where the value of the portfolios exceeds €50,000 at any time during the year (Article 1736, X of the French Tax Code), in addition to late payment interest on the tax evaded (Article 1727 of the French Tax Code).
How does a French CASP prepare for its first DAC 8 report in 2027?
Four workstreams to carry out from 2026: (1) Enhanced KYC: collect the TIN, tax residence and CRS self-certification of each user; (2) Technical infrastructure: export transactions in CRS-rev / DPI 2.0 XML format; (3) Reconciliation: aggregate transactions per user per financial year, distinguishing disposals, crypto-to-crypto exchanges, staking and airdrops; (4) Governance: appoint a DAC 8 lead and formalise the internal process. Penalties: a fine of €15 per transaction not reported or reported late, or per inaccuracy, up to a limit of €2,000,000 per provider per reporting year (Article 1736, I, 6 of the French Tax Code), and a fine of up to €50,000 for a failure to meet the due diligence obligations (Article 1736, XV of the French Tax Code).
Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants. Certified Pennylane trainer.
Regulated French accounting firm based in Paris 8, whose founder is also a statutory auditor, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
- Légifrance — Décret n° 2025-1276 du 19 décembre 2025 (obligations PSAN/CASP, articles 1649 AC bis à sexies CGI)
- Légifrance — Décret n° 2025-1277 du 19 décembre 2025 (norme commune de déclaration révisée)
- AMF — Régulation MiCA et transition PSAN/CASP (fin du transitoire 1er juillet 2026)
- Légifrance — Ordonnance n° 2024-936 du 15 octobre 2024 relative aux marchés de crypto-actifs
- Légifrance — CGI article 150 VH bis (régime fiscal cessions cryptoactifs)
This topic is part of our service Tax accountant in Paris | CIT, VAT & tax audits
Need a quote or personalised advice?
Our accountancy firm supports you through all your steps. Get a free quote to review your situation and receive a bespoke fee proposal, or contact us directly.