France's MiCA Revision Proposals: What the AMF, ACPR, Banque de France and Treasury Want Changed
On 21 October 2026, France's four principal financial authorities, the Autorité des marchés financiers (AMF), the Autorité de contrôle prudentiel et de résolution (ACPR), the Banque de France and the Direction générale du Trésor, published a joint response to the European Commission's consultation on revising the Markets in Crypto-Assets Regulation. The document sets out a coherent French position on where MiCA needs to be sharpened, and it covers ground that matters directly to compliance officers, CFOs, audit teams, and anyone managing MiCA compliance crypto obligations for an EU-facing business. The proposals are not law yet, but at 92 on the relevance scale they represent a clear signal of where the EU rulebook is heading.
Why France Is Pushing for a MiCA Revision Now
MiCA has been fully applicable since the end of 2024, but the regulation was written before the market matured and before the boundary cases became obvious. The French authorities are not calling for MiCA to be torn up. Their central thesis is that crypto and traditional finance are converging rapidly, and that convergence requires better articulation between the two legal regimes rather than a merger of them.
The "same activity, same risk, same rule" principle, applied carefully
The joint paper defends a clear line: if an instrument is a financial instrument under existing securities law, it must remain fully governed by securities law regardless of whether it is issued or traded on a blockchain. Technology is irrelevant to legal classification. The same logic applies to payment instruments. This is a deliberate pushback against regulatory arbitrage, where an issuer might claim MiCA treatment to escape the heavier conduct and capital requirements that apply under MiFID II or the Payment Services Directive.
For accounting and legal teams, the practical implication is straightforward: the tokenisation of an asset does not change its accounting classification or its regulatory treatment. A tokenised bond is still a bond. A tokenised deposit is still a deposit. Firms that have been treating wrapped or tokenised versions of regulated instruments as if MiCA applied should review those positions.
Stablecoin Accounting and the Multi-Issuance Problem
The most technically precise section of the French proposals addresses what the authorities call "multi-issuance" of e-money tokens (EMTs). This refers to the practice of issuing fungible tokens simultaneously inside the EU under MiCA and in third-country jurisdictions under whatever local rules apply there, or no rules at all.
What the French authorities propose for cross-border EMTs
The authorities want a formal framework built around three pillars. First, equivalence assessments: the Commission would evaluate whether a third country's stablecoin regime offers a genuinely comparable level of protection. Second, supervisory cooperation agreements between EU authorities and their counterparts in those third countries. Third, additional guarantees on reserve quality and redemption rights for tokens that circulate across jurisdictions.
For stablecoin accounting teams, this matters because the reserve and redemption obligations attached to a multi-issued token may differ depending on which tranche is being accounted for and under which regime. Firms already holding or processing EMTs such as USDC should monitor this closely: the EBA's designation of USDC as the EU's first significant e-money token already placed heightened obligations on issuers and service providers, and the French multi-issuance framework would add another layer of cross-border conditions on top of that designation.
The ban on servicing non-compliant tokens
The French authorities also propose that EU-licensed crypto-asset service providers (CASPs) be explicitly prohibited from offering services on tokens that do not meet MiCA requirements. This would codify what many compliance teams already treat as best practice but make it a binding prohibition. Any CASP currently listing or custodying tokens whose issuer has not obtained the relevant EMT or ART authorisation should treat this proposal as a compliance gap that may need closing before the next review cycle.
Monetary Sovereignty and the Role of CBDCs
A thread running through the entire document is euro monetary sovereignty. The French authorities are explicit: they want to accelerate the use of euro-denominated EMTs and tokenised bank deposits, particularly for cross-border payments with third countries and for tokenised finance more broadly.
Wholesale CBDC as the anchor settlement asset
Critically, the paper is careful to say that none of this comes at the expense of central bank money. The European Central Bank's Pontes infrastructure for wholesale central bank digital currency (CBDC) is already live, and the digital euro retail project is in progress. The French position is that commercial bank EMTs and tokenised deposits are complements to, not substitutes for, wholesale CBDC. For financial transactions involving tokenised assets, central bank money remains the preferred settlement asset because it carries no credit risk.
For firms building settlement infrastructure or advising clients on digital asset accounting software choices, this hierarchy matters. Regulatory capital treatment, settlement finality, and counterparty risk analysis all look different depending on whether the settlement leg uses a CBDC, a regulated EMT, or an unregulated stablecoin. The French proposals reinforce a clear preference for the first two.
Stronger ESMA Oversight of Significant CASPs and Crypto-Conglomerates
On supervision, the French authorities propose expanding the direct supervisory remit of the European Securities and Markets Authority. Currently, ESMA has coordination and standard-setting functions under MiCA, but day-to-day supervision sits with national competent authorities. The French position is that CASPs that are significant, by virtue of size, cross-border reach, or systemic footprint, should fall under direct ESMA oversight, alongside crypto-conglomerates for their crypto-related activities.
Prudential calibration and enforcement against unlicensed providers
The joint paper also calls for prudential requirements to be calibrated to actual risk rather than applying uniform capital buffers across all CASP categories. Alongside that, the authorities want coordinated EU-wide enforcement against unlicensed providers operating into the EU from outside, which they view as a significant investor protection gap. For compliance and audit teams advising firms on MiCA compliance crypto programmes, both proposals are relevant: more proportionate prudential rules could reduce compliance costs for smaller or lower-risk CASPs, while stricter enforcement against unlicensed competitors levels the playing field.
DeFi: A Regulated Framework, Not a Carve-Out
The French authorities take a clear position on decentralised finance: they want it brought within a proportionate regulatory framework rather than left in an ambiguous zone. This aligns with what compliance teams have been anticipating given the broader EU debate, and it connects directly to the question of DeFi accounting, since classification and reporting obligations depend on whether a protocol or its deployers are treated as regulated entities.
What the DeFi framework would require
The proposals set out three elements for a DeFi framework. Intermediaries must have clearly attributed responsibilities, so that there is always an identifiable legal person accountable to regulators and users. Due diligence obligations must be adapted to the decentralised context, accepting that the traditional CASP model does not map cleanly onto automated protocols. Finally, protocols themselves should be subject to a certification or conformity process, giving users a degree of assurance about the code they interact with.
For accounting and audit teams, the attribution of responsibility to identifiable intermediaries is the most consequential element. If a DeFi deployer or front-end operator is treated as a regulated entity, it creates an audit trail, counterparty, and potentially a consolidation question. Teams working on DeFi and traditional finance convergence in the EU will recognise that this regulatory direction requires digital asset accounting software capable of mapping on-chain activity to identified legal entities.
Staking, lending and borrowing: clarity coming
The document singles out staking, defined as the immobilisation of crypto-assets in exchange for a return, and crypto lending and borrowing, as areas requiring specific regulatory clarification within the revised MiCA framework. These activities sit in a grey zone today: they are economically significant, they carry distinct risks for participants, and the accounting treatment varies depending on whether the arrangement is classified as a deposit, a repo, a service contract, or something else entirely. A clearer regulatory definition will anchor the accounting classification, which is why this proposal is particularly relevant for firms that hold staked positions on behalf of clients or that engage in crypto lending as a treasury activity.
Implications for Compliance Teams and CFOs
These are proposals, not final rules, and they must still go through the EU legislative process. But the French position, backed by four heavyweight authorities, carries significant weight in the Commission's deliberations. Compliance officers and CFOs at firms with EU exposure should take several practical steps now rather than waiting for formal amendments.
Actions to take ahead of formal amendment
First, audit your CASP relationships. The proposed ban on servicing non-MiCA-compliant tokens means that any custody, trading, or settlement arrangement involving tokens from unlicensed issuers carries elevated regulatory risk. Second, review your EMT and stablecoin reserve documentation. If the multi-issuance equivalence framework is adopted, expect supervisors to ask questions about the reserve quality and redemption terms of cross-border tokens. Third, map your DeFi exposures. Even if formal DeFi rules are still being shaped, the French proposal's emphasis on identifiable intermediary responsibility suggests that supervisors will be looking for an accountable entity behind every significant DeFi position. Fourth, monitor the ESMA expansion discussion. If direct ESMA supervision of significant CASPs becomes law, the supervisory relationship and reporting cadence will change, and firms need to plan for that.
The overall direction is clear: MiCA is not going away, it is getting more detailed. Firms that build robust MiCA compliance crypto programmes now, covering stablecoin accounting, DeFi exposure mapping, and CASP due diligence, will be better positioned when the revised framework takes effect.
Frequently Asked Questions
What is the French joint MiCA revision proposal?
It is a coordinated response from the AMF, ACPR, Banque de France and the Treasury (Direction générale du Trésor) to the European Commission's MiCA review consultation, published on 21 October 2026. It sets out France's preferred changes to the regulation across stablecoins, DeFi, CBDC, supervision and cross-border equivalence.
Does this change my current MiCA compliance obligations?
Not yet. The proposals are not law. They form part of the Commission's consultation process and would require a formal legislative amendment to MiCA before they become binding. However, they signal supervisory priorities, and national competent authorities may apply existing rules more strictly in the areas the proposals highlight.
What does "multi-issuance" mean for stablecoin accounting?
Multi-issuance refers to an EMT issuer distributing fungible tokens both inside the EU under MiCA and in third countries under different or no rules. The French proposal would require equivalence assessments and additional reserve guarantees for such tokens. For accounting purposes, firms need to distinguish which tranche of a multi-issued token is subject to which reserve and redemption obligations when valuing or disclosing holdings.
How would the proposed DeFi framework affect my firm?
If adopted, the framework would require identifiable intermediaries, such as protocol deployers or front-end operators, to carry regulatory responsibilities. Firms that interact with DeFi protocols, whether as liquidity providers, treasury managers, or service providers, may find that counterparties become regulated entities, changing the accounting classification, risk weighting, and disclosure requirements for those positions.
Why do the French authorities want ESMA to have direct supervisory powers over significant CASPs?
The rationale is investor protection and cross-border consistency. Significant CASPs operate across multiple EU member states, and national supervision can create gaps or inconsistencies. Direct ESMA oversight, modelled loosely on its role over credit rating agencies and certain trade repositories, would create a single supervisory contact point for the largest players and enable more coordinated enforcement against unlicensed operators.