AMF 2025 Annual Report: MiCA Compliance, Tokenisation and What It Means for Crypto Firms

France's financial markets regulator, the Autorité des marchés financiers (AMF), released its 2025 annual report on 28 May 2026, and for crypto-asset service providers operating in or targeting France, the message is direct: MiCA authorisation files are being processed under full operational pressure, asset tokenisation is being treated as a strategic national priority, and cyber resilience expectations are about to get sharper. Accounting firms, auditors, and CFOs advising digital asset businesses need to read the signals carefully.

Three Strategic Priorities Shaping the AMF's 2025 to 2026 Agenda

AMF president Marie-Anne Barbat-Layani framed the regulator's work around three overarching goals: building a safer and more resilient French financial centre, deepening European capital markets and reinforcing Paris's attractiveness, and creating conditions for innovative finance to develop responsibly. These are not abstract ambitions. Each one has concrete implications for firms handling digital assets.

Market Resilience Under Geopolitical Stress

The AMF acknowledges that financial markets have navigated several stress episodes since the escalation of conflict in the Middle East, doing so in an orderly way so far. But the regulator is explicit that vulnerabilities identified in its 2025 risk mapping remain active, including those tied to the growth of private finance. For crypto firms, the relevance is indirect but real: a regulator already on high alert for systemic fragility will apply heightened scrutiny to any asset class seen as amplifying risk.

Cyber Risk and AI-Driven Threats

The AMF president specifically called out the acceleration of cyber risk linked to new AI models. The regulator has indicated it will publish a dedicated communication on cyber resilience in the near term, covering actions it plans to take over the coming months. Firms in the crypto space, where smart contract exploits and AI-assisted social engineering are live threats, should treat this as an early signal to review their own cyber governance frameworks before any formal guidance lands.

MiCA Compliance Crypto: Where the AMF Stands Now

The annual report confirms that AMF teams are fully engaged in processing authorisation applications submitted under the Markets in Crypto-Assets Regulation (MiCA). With the transitional period drawing to a close, the workload is real and the regulator is not understating it. Barbat-Layani described teams as "fully mobilised" on MiCA dossiers.

What This Means for Firms Awaiting Authorisation

Any crypto-asset service provider that submitted a MiCA authorisation application to the AMF should be prepared for detailed back-and-forth. The AMF's posture is one of rigorous examination, not rubber-stamping. Firms that have not yet filed and intend to operate in France after the transitional window closes face an increasingly compressed timeline. The MiCA transitional period expiry and mandatory CASP authorisation deadline is not a soft date.

For accounting and audit teams supporting these applications, the documentation burden is substantial. Financial statements, internal control descriptions, AML/CFT policies, and capital adequacy evidence all form part of the authorisation package. Stablecoin accounting treatment, particularly for euro-referenced e-money tokens (EMTs) and asset-referenced tokens (ARTs), is a live question: MiCA imposes specific reserve asset rules that must be reflected accurately in a firm's books. Getting the crypto compliance reporting architecture right before submission is not optional.

Stablecoin Accounting Under MiCA's Reserve Requirements

For firms issuing or holding stablecoins that qualify as EMTs or ARTs under MiCA, the accounting treatment carries regulatory weight. Reserve assets must be segregated, valued at market, and reported in a way that demonstrates ongoing coverage of redemption obligations. Auditors signing off on these firms need to understand how those reserves are classified on the balance sheet and what disclosures MiCA Article 36 and related technical standards require. Sloppy stablecoin accounting is not just an accounting problem at this point, it is a licensing risk.

The AML dimension of stablecoin compliance is equally live. Illicit finance risks tied to certain stablecoin arrangements, as illustrated by enforcement action elsewhere in Europe, reinforce why the AMF is processing MiCA files with care. Firms should also review our earlier coverage of Huione Group illicit marketplace and USDH stablecoin AML risk as a reference point for how regulators view stablecoin abuse patterns.

Asset Tokenisation: Paris Wants to Lead

One of the most commercially significant signals in the report is the AMF's explicit ambition to position Paris at the forefront of financial asset tokenisation. Barbat-Layani described 2026 as "a key year" for tokenisation, noting its potential to open new financing and liquidity possibilities. The AMF intends to actively contribute to making Paris a first-rank hub for this transformation.

Accounting and Audit Implications of Tokenised Securities

Tokenised financial instruments, whether representing bonds, fund units, or equity, sit in a complex accounting and audit space. The underlying economic substance must drive the accounting treatment, not the token wrapper. A tokenised bond is still a bond for IFRS purposes. But the custody arrangements, the settlement finality, and the smart contract logic all introduce novel audit considerations that standard securities audit programmes do not cover. Firms advising asset managers or issuers exploring tokenisation in France should be building those technical audit capabilities now, not after the first mandate lands.

The EU Capital Markets Union Context

The AMF's tokenisation push sits within a broader European policy agenda. The regulator explicitly backs the Savings and Investment Union project, the EU's effort to deepen and integrate capital markets across member states. Tokenisation is seen as a mechanism to improve cross-border liquidity and reduce friction in securities settlement. For firms with EU-wide client bases, this means the regulatory and accounting questions around tokenised assets are not a French-only issue. ESMA's ongoing clarifications, including on ESMA white paper exemption guidance for non-ART and non-EMT offerings, are part of the same ecosystem.

Investor Protection and Market Integrity: The Enforcement Backdrop

The AMF also used the annual report to restate its commitment to investor protection and market integrity. The regulator flagged the spread of financial scams, the rise of insider trading networks, and the ongoing democratisation of stock market investing among retail participants. A third phase of its investor education campaign, focused on the message that "investing is not a game", is planned for autumn.

For crypto firms specifically, this enforcement backdrop matters. The AMF has a track record of sanctions in the digital asset space, and its annual report signals no softening of that posture. Firms operating platforms that could be used for market manipulation, or that serve retail investors without adequate disclosures, face a regulator that is actively scanning for those failures. The Labaronne legislative proposal, which the AMF is calling on Parliament to adopt quickly, would give the regulator additional legal tools to act faster and with greater force against financial insecurity.

Practical Takeaways for Accounting Firms and CFOs

The AMF 2025 annual report is not a technical regulatory text. It is a statement of intent. But the intent has direct operational consequences for firms in the crypto-accounting and audit space.

Priority Actions to Consider Now

• Review MiCA authorisation file completeness if your client has a pending AMF application. The regulator is processing these under pressure and incomplete files will create delays.
• Stress-test stablecoin accounting policies against MiCA reserve asset requirements. Segregation, valuation methodology, and disclosure adequacy all need to stand up to regulatory scrutiny.
• Assess cyber governance frameworks in light of the AMF's forthcoming cyber resilience communication. Do not wait for the guidance to arrive before starting the review.
• Build tokenised asset audit capability if you have clients in the asset management or securities issuance space. The AMF is actively encouraging this market and mandates will follow.
• Monitor the Labaronne proposal through the French legislative process. If adopted, it will expand the AMF's enforcement toolkit and could affect how quickly the regulator can act against firms it has concerns about.

Source: Autorité des marchés financiers (AMF)

What is the AMF's current position on MiCA authorisation applications?

The AMF has confirmed its teams are fully engaged in processing MiCA authorisation dossiers as the transitional period ends. The regulator is applying rigorous examination standards, meaning firms should expect detailed review and potential requests for additional information before any authorisation is granted.

How does the AMF's tokenisation agenda affect crypto accounting?

The AMF is positioning Paris as a leading centre for financial asset tokenisation in 2026. For accountants and auditors, this means tokenised securities mandates are likely to increase. The accounting treatment follows the economic substance of the underlying instrument under IFRS, but custody, settlement, and smart contract features introduce new audit considerations that standard frameworks do not yet fully address.

What does the AMF report say about stablecoin risks?

The report does not address stablecoins in isolation, but the MiCA processing workload implicitly covers EMT and ART issuers. Stablecoin accounting under MiCA requires reserve asset segregation and valuation to meet redemption obligations, and auditors must verify compliance with MiCA's reserve rules as part of any engagement covering stablecoin-issuing clients.

What is the Labaronne proposal and why does it matter for crypto firms?

The Labaronne proposal is a French legislative bill the AMF is actively pushing Parliament to adopt. It would give the regulator new legal tools to act more quickly and forcefully against financial misconduct. If passed, it could shorten the timeframe between the AMF identifying a concern and taking formal enforcement action, which has direct relevance for any firm operating in the French crypto market.

How should firms prepare for the AMF's upcoming cyber resilience communication?

The AMF has signalled it will publish guidance on cyber resilience and AI-related threats in the near term. Firms should not wait for that publication before reviewing their own cyber governance. A gap analysis against existing DORA requirements and the AMF's general supervisory expectations is a reasonable starting point, given that DORA obligations apply to many financial entities operating in the EU.