France AMF CASP Authorisation: The PSAN Transition to MiCA

France was early — and now has to converge

France did not wait for MiCA. The 2019 PACTE law created the PSAN regime — Prestataire de Services sur Actifs Numeriques — one of the first dedicated national crypto frameworks in the EU. For years, a French PSAN registration was a recognisable mark in the European crypto market.

MiCA changed the picture. As an EU regulation, MiCA superseded the PSAN regime as a standalone national framework from 30 December 2024. France now runs the standard MiCA CASP regime, supervised by the Autorite des marches financiers (AMF) — and existing PSANs have to converge onto it.

The two tiers of the old PSAN regime

Understanding the transition starts with understanding what a firm is transitioning from. The PACTE-law PSAN regime had two levels:

• Basic registration — mandatory for custody, crypto-to-fiat and crypto-to-crypto exchange, and operating a trading platform. A lighter regime focused on AML/CFT and fit-and-proper checks.
• Enhanced authorisation (the agrement, later re-framed as enhanced DASP registration) — optional, with a fuller set of prudential, governance, and conduct requirements closer to MiCA’s standard.

That distinction matters for the transition, because a firm’s starting tier drives how much ground it has to cover to reach MiCA CASP standard.

The deadline: 1 July 2026, with criminal liability

France used the full 18-month transitional window under MiCA’s transitional regime. The transitional period that lets existing French DASPs continue providing crypto-asset services without a MiCA authorisation ends on 1 July 2026.

After that date, only firms holding a granted MiCA CASP authorisation may provide crypto-asset services in France. The AMF has been explicit about the consequence of operating without one: it is a criminal matter, not merely a civil or administrative one. A provider continuing to operate in France after the deadline without a CASP authorisation faces criminal liability.

The practical reading: the deadline is for being authorised, not for having filed. A firm that submits an application in June 2026 and is still in assessment on 1 July is not compliant.

The fast-track for existing PSANs

The AMF has not made existing PSANs start from zero. The AMF’s transition policy treats much of the content already filed under the PACTE regime as MiCA-compliant, subject to adjustment — a genuine fast-track for firms already inside the French regime.

Practitioner-reported end-to-end timelines:

Starting point	Fast-track timeline (practitioner-reported)
Enhanced DASP holder	~3-5 months
Basic PSAN registrant	~4-6 months

The gap between the two reflects the gap in the starting regimes. An enhanced DASP holder already filed a fuller prudential and governance set; a basic registrant has more to build — MiCA-standard governance, prudential capital evidence, ICT-resilience documentation, the complaints-handling procedure — to reach the CASP bar.

What the transition actually requires

Even on the fast-track, a French CASP application is a real MiCA file. The fast-track reuses prior content; it does not waive the substance. A transitioning PSAN should expect to demonstrate:

1. Prudential capital to the MiCA Annex IV class floor, plus the ongoing fixed-overheads-based requirement
2. MiCA-standard governance — management body suitability, conflict-of-interest arrangements
3. ICT resilience under DORA
4. AML/CFT framework — much of which a PSAN already has, given the PSAN regime’s AML focus
5. Complaints handling under MiCA’s complaints-handling obligation
6. The custody, market-abuse, or trading-platform obligations relevant to the firm’s licence class

For a basic PSAN registrant, the items least likely to exist in usable form are the prudential, governance, and ICT-resilience workstreams — the parts the lighter basic regime did not demand.

How France compares as a CASP home

France is a large, credible CASP jurisdiction with an established regulator and an early-mover crypto history. For a firm already holding a French PSAN registration, transitioning in France via the fast-track is usually the obvious path — the firm already has French substance, French counsel relationships, and prior AMF engagement.

For a firm with no existing French footprint, choosing France as a fresh CASP home is a different calculation, weighed against the other EU jurisdictions in the same way the rest of this publication’s jurisdiction coverage sets out.

Working with counsel on a French transition

The diagnostic for counsel: ask whether they can map, for the specific firm, exactly which of its existing PSAN filings the AMF will accept as MiCA-compliant and which need rebuilding — and whether the realistic timeline clears 1 July 2026 with margin. Counsel that treats the fast-track as automatic has misread it. The firms in our index with relevant French and multi-jurisdiction experience are listed below.