France's MiCA Transition Is Over: What the AMF's New Supervisory Role Means for Accounting Firms and CFOs
As of 2 July 2026, the transitional window that allowed French crypto-asset service providers to operate under the pre-existing national registration regime introduced by the Loi Pacte has closed. The Markets in Crypto-Assets Regulation (MiCA) now applies without exception to every operator offering crypto-asset services in France and across the European Union. For accounting firms, auditors, and CFOs with clients in this space, the regulatory landscape has shifted materially: there is no longer a two-tier system, and the Autorité des marchés financiers (AMF) has formally pivoted from a licensing intake function to active, ongoing supervision of authorized crypto-asset service providers (CASPs).
What the End of the Transition Actually Means
MiCA entered into force for CASP operators on 30 December 2024, but providers that were already registered or licensed under the Loi Pacte framework as prestataires de services sur actifs numériques (PSANs) were granted an 18-month runway to obtain full MiCA authorization. That runway expired on 1 July 2026.
The hard deadline and its consequences
From 2 July 2026, any firm that has not received a MiCA authorization and continues to offer crypto-asset services to EU clients is operating outside the law. There is no grace period, no grandfather clause, and critically, MiCA contains no equivalence regime for third-country providers. A non-EU-authorized CASP cannot legally passport services into France or any other EU member state.
The AMF has been explicit: it will monitor the orderly wind-down plans of operators that failed to secure authorization, and it is coordinating closely with the European Securities and Markets Authority (ESMA) and other national competent authorities to ensure those processes protect client interests above all else. ESMA issued a parallel statement calling on unauthorized CASPs to wind down in an orderly fashion while safeguarding clients, which aligns directly with the AMF's stated priority.
France's position in the EU authorization landscape
The AMF confirmed that France has authorized 31 CASPs under MiCA as of the announcement date, with a small number of additional applications still being finalized. Across the EU as a whole, 283 authorizations have been granted. France is the second-largest home jurisdiction for MiCA-authorized CASPs in the EU, a direct consequence of the relatively mature PSAN registration framework that the Loi Pacte established years before MiCA came into force.
How MiCA Raises the Bar Beyond the Loi Pacte
The Loi Pacte was pioneering for its time. At a minimum, it required registered PSANs to maintain an anti-money laundering and counter-terrorist financing (AML/CTF) framework. MiCA goes significantly further across several dimensions that have direct implications for how firms record, report, and audit CASP activities.
Expanded conduct and prudential obligations
MiCA mandates conduct-of-business rules, market abuse prevention controls, and information security standards that were largely absent from the Loi Pacte regime. It also introduces specific requirements for the safekeeping of client crypto-assets and client funds, as well as formal complaint-handling procedures. For CFOs at authorized CASPs, these obligations translate into new internal control frameworks, documented policies, and potentially additional capital or liquidity buffers depending on the services offered.
For accounting firms auditing or advising MiCA-authorized entities, the practical effect is an enlarged audit perimeter. Client asset segregation requirements under MiCA create distinct balance sheet and off-balance-sheet considerations. Safeguarded client crypto-assets held by a CASP must be clearly distinguished from the CASP's own proprietary holdings, and the accounting treatment of those positions, particularly in terms of recognition, measurement, and disclosure, demands careful attention. Robust crypto compliance reporting processes and reliable crypto accounting software capable of capturing CASP-specific transaction flows are no longer optional infrastructure: they are operational prerequisites for meeting MiCA's record-keeping expectations.
Investor protection as a regulatory design principle
The AMF explicitly frames MiCA's additional requirements as investor protection measures. The safeguarding rules, claims procedures, and market integrity obligations are all oriented toward the same goal: ensuring that retail and institutional clients of CASPs can rely on a predictable, regulated environment. For accounting professionals advising clients who invest through CASPs, this has a practical upside: the quality and completeness of transaction records that CASPs are now required to maintain should improve the accuracy of cost-basis data and make year-end tax and reporting work more tractable.
The AMF's Shifted Role: From Gatekeeper to Supervisor
During the transition period, the AMF's primary function in the crypto space was processing authorization applications and managing the legacy PSAN register. That intake phase is now largely complete. The AMF has signaled clearly that its teams are pivoting to supervisory work: monitoring whether authorized CASPs are meeting their ongoing professional and conduct obligations under MiCA on a continuous basis.
What supervisory escalation looks like in practice
Active supervision means the AMF can examine CASP operations, request documentation, and initiate enforcement proceedings for breaches of MiCA obligations. This is a materially different posture from the registration era, where regulatory interaction was concentrated at the point of entry. Accounting firms that serve CASP clients should expect that AMF supervisory visits and information requests will become a routine feature of the landscape, rather than a rare occurrence. Audit files and management accounts should be prepared accordingly.
The AMF also retains its authorization function: it will continue processing new CASP applications submitted after the transition end date with the same level of scrutiny it applied during the transition. Firms looking to enter the French market as MiCA-authorized operators still have a clear pathway, but there is no expedited or simplified track now that the transitional window has closed.
AML Obligations on Client Transfers: A Specific Risk for Authorized CASPs
One of the most operationally significant points in the AMF's announcement concerns client transfers from winding-down unauthorized operators to authorized CASPs. The AMF has drawn explicit attention to the AML/CTF due diligence requirements that apply when an authorized CASP takes on new clients in the context of a PSAN or unauthorized operator wind-down.
Why this transfer scenario creates elevated AML risk
When a CASP ceases operations and its client base migrates to an authorized provider, the receiving CASP cannot simply accept those clients and their assets at face value. The AMF reminds authorized CASPs that they must conduct all applicable regulatory checks before onboarding transferring clients, including full AML/CTF verification. The concern is straightforward: a disorderly or inadequately supervised wind-down could facilitate the movement of assets that have not been properly screened, creating downstream compliance exposure for the receiving entity.
For accounting firms and compliance teams at authorized CASPs, this means the client onboarding procedures triggered by wind-down transfers must be treated as high-risk events, not routine account openings. Enhanced due diligence, source-of-funds documentation, and transaction history reviews are all likely to be relevant. Digital asset accounting software that can ingest and reconcile transaction histories from multiple prior custodians will be essential for constructing an accurate picture of a transferring client's portfolio and cost basis. This is directly relevant to how firms choose and configure their crypto accounting software stack in the context of MiCA CASP compliance.
No equivalence with third-country providers
The AMF reiterates a point that carries significant weight for any client currently using a non-EU-authorized CASP: MiCA does not include an equivalence regime. There is no mechanism by which a CASP authorized in, say, a non-EU jurisdiction can be treated as MiCA-compliant for the purpose of offering services in France or the EU. Clients who are using unauthorized or third-country providers after 1 July 2026 are doing so outside the protection of MiCA's investor safeguards. Accounting firms should flag this clearly in client communications, particularly where those clients' crypto holdings are material to their financial position or tax exposure.
Practical Steps for Accounting Firms and CFOs
The transition end date is not an administrative milestone to be noted and filed. It has concrete implications for how firms should be operating right now.
Immediate compliance checklist
First, verify the authorization status of every CASP your clients use or that your firm audits. The AMF and ESMA maintain public registers of MiCA-authorized entities. Any client relationship with an unauthorized CASP needs to be addressed urgently, either by migrating to an authorized provider or by documenting the exposure and advising the client of the legal position.
Second, review the audit scope for CASP clients. The expanded MiCA obligations around client asset safeguarding, market abuse controls, and complaint handling all create new areas of audit risk. Engagement letters and audit plans should be updated to reflect these additional dimensions. Digital asset accounting software used to support the audit must be capable of distinguishing client assets from proprietary assets and of producing the transaction-level records that MiCA's record-keeping requirements demand.
Third, for CFOs at CASPs that have received MiCA authorization, begin the work of embedding ongoing compliance into operational routines. MiCA supervision is live. The AMF is no longer simply reviewing applications; it is monitoring whether the commitments made during the authorization process are being honored. Internal compliance calendars, management information packs, and board reporting should all reflect the new supervisory environment. Firms looking for a broader view of how CASP authorization under MiCA operates across EU jurisdictions will find the contrast between the French and Liechtenstein experiences instructive.
Fourth, prepare for the AML complexity of client transfer events. Any authorized CASP that anticipates receiving clients from winding-down operators should build a specific onboarding procedure for that scenario, one that treats it as elevated-risk by default and ensures cost-basis and transaction history data is captured accurately from day one.
Frequently Asked Questions
What happened on 1 July 2026 for French crypto-asset service providers?
The transitional period that allowed providers registered under France's Loi Pacte PSAN framework to continue operating while seeking MiCA authorization expired on 1 July 2026. From 2 July 2026, MiCA applies to all CASP activities in France and across the EU without exception. Operators without a MiCA authorization may no longer legally provide crypto-asset services to EU clients.
How many CASPs has France authorized under MiCA?
As of the AMF's announcement of 6 July 2026, France had granted MiCA authorization to 31 CASPs, with a small number of additional applications still in the finalization stage. France is the second-largest home jurisdiction for MiCA-authorized CASPs in the EU, where 283 authorizations have been issued in total.
What are the AML obligations when a CASP takes on clients from a winding-down operator?
The AMF has specifically reminded authorized CASPs that they must complete all applicable regulatory and AML/CTF due diligence checks before accepting clients who are transferring from a CASP that is winding down. These transfers should be treated as elevated-risk onboarding events, requiring enhanced due diligence, source-of-funds checks, and thorough transaction history reviews.
Does MiCA recognize third-country CASP authorizations as equivalent?
No. MiCA contains no equivalence regime for non-EU jurisdictions. A CASP authorized outside the EU cannot use that authorization to offer services legally in France or any other EU member state. Clients using non-EU-authorized providers after 1 July 2026 do so outside MiCA's investor protection framework.
What does the AMF's new supervisory role mean for CASP audits?
The AMF has formally shifted from primarily processing authorization applications to actively supervising authorized CASPs' ongoing compliance with MiCA's professional and conduct obligations. For accounting firms, this means audit scopes for CASP clients must now cover client asset safeguarding, market abuse controls, complaint handling, and information security requirements. AMF supervisory requests and inspections should be anticipated as a routine feature of operating as or auditing a MiCA-authorized CASP in France.