These 40 questions help French businesses organise their decisions, transactions and records. Answers concern the French framework and should be read in light of the entity, contract and financial year. Personal and company holdings must be assessed separately.
Treasury and structure
1. Can a company buy crypto-assets?
A company may consider holding assets for its own account, subject to its objects, authority and sector rules. The decision must serve the business’s interests and account for its commitments. Providing services to clients raises different obligations.
2. Is shareholder approval required?
This depends on the articles of association, directors’ powers and the transaction. A reasoned decision records the assessment and necessary approvals. It does not, by itself, guarantee that a director cannot be liable.
3. How much treasury can be exposed?
There is no universal percentage suitable for every business. Start with payroll, tax, suppliers, repayments and unexpected needs. Price volatility, withdrawal restrictions and the possibility of losing the investment belong in the cash-flow assessment.
4. Is a holding company always preferable?
No. A holding company can organise certain investments but adds costs and obligations and does not isolate every risk. The choice depends on funding, the group, objectives and tax treatment. Compare structures before incorporating.
5. Should the company’s objects be amended?
First review the existing objects and actual transactions. Own-account investment, regular trading and third-party services require different assessments. Broad wording does not replace a regulatory authorisation where one is required.
6. Can the director use a personal account?
Dedicated company accounts and wallets support ownership evidence. Mixing assets creates documentation difficulties and reclassification risks. If transactions have already occurred, establish their nature and funding before making corrections.
Accounting
7. Which accounting framework applies?
Identify the entity’s framework and financial year. ANC Regulation 2026-01 applies to years starting on or after 1 January 2027; early adoption is permitted for the year in progress at its publication in the Official Journal on 3 September 2026.
8. Do all crypto-assets use the same account?
No. Rights, classification and use determine the treatment. Regulation 2026-01 distinguishes financial instruments, e-money tokens, rights used in operations and other crypto-assets. A commercial label is insufficient.
9. How are stablecoins treated?
Classify the exact token. Under Regulation 2026-01, e-money tokens as defined by MiCA use account 513. Automatically putting all stablecoins in account 522, or treating all of them as bank deposits, would be incorrect.
10. Should records distinguish each asset and platform?
Yes: records must support reconciliation of quantities and balances. Subaccounts or a subsidiary register linked to the general ledger can provide that detail. Distinguish available, blocked, lent and pledged assets.
11. How should assets be valued at year-end?
Apply the rules for the framework and asset category. Document reliable sources, date, time and liquidity limitations. An unsuitable method does not become correct merely because it is used consistently.
12. Do unrealised gains always enter profit or loss?
No. Treatment depends on the asset. For account 522 crypto-assets, Regulation 2026-01 uses transitional accounts for valuation movements and specifies the treatment of unrealised losses. Tax consequences need a separate assessment.
13. Do gas fees always increase acquisition cost?
No. Identify the transaction and framework. Article 619-10 of Regulation 2026-01 expenses ancillary acquisition costs for the assets it covers. Also retain the quantity of crypto used to pay those fees.
14. Does specialist software replace accounting review?
No. It supports collection and reconciliation, but duplicates, transfers, rewards and complex transactions require checks. Choosing a spreadsheet or specialist tool depends on volume and complexity, not a universal transaction threshold.
Tax and reporting
15. Is a crypto-to-crypto exchange neutral for corporation tax?
Do not apply the deferral available for certain individual exchanges to a corporation-tax company. Record the asset given up and the asset received and determine their effect. An internal transfer without a change of owner is different.
16. Which tax rate applies to the company?
The result follows the company’s tax regime, including corporation tax where applicable and any conditions for a reduced rate. The individual flat-rate regime is not the tax rate for a company’s portfolio.
17. How should staking rewards be treated?
Identify the mechanism, rights acquired, availability date and valuation. Treatment depends on the contract and entity’s regime. Distinguish a reward, the return of a deposit and a disposal gain, using supporting records.
18. Does VAT disappear when a customer pays in crypto?
No. The payment method does not by itself change the VAT treatment of the underlying supply. Exemptions for certain exchange transactions are not a general exemption for goods, services or crypto-sector activities.
19. Does company mining require specific accounting work?
The entity’s regime applies, with specific attention to equipment, hosting, energy, contracts and revenue. A machine’s profitability is not measured solely by tokens produced. Reconcile invoices and mining-pool flows.
20. Must foreign crypto accounts be reported?
Article 1649 bis C covers persons or entities established in France and relevant portfolios opened, held, used or closed with foreign organisations. Check the contracting entity, scope and procedures; having no disposals does not by itself remove the obligation.
21. Does platform reporting replace my own filings?
No. DAC8 includes collection of 2026 data and the first exchanges between authorities in 2027. The company’s own filing and accounting-evidence obligations remain. Automated reporting can also require data corrections.
Payments and invoicing
22. Can payment in bitcoin or a stablecoin be agreed?
Yes, where the counterparty agrees and applicable rules are respected. Specify the network, token, fees, validity period of the quoted amount and treatment of insufficient or late payments.
23. Must an invoice be exclusively in euros?
French rules permit invoices in another currency subject to conditions, with VAT payable determined in euros. Crypto settlement does not remove the tax base, mandatory details or an evidenced equivalent value. Distinguish invoicing currency from payment method.
24. Which price should be used for a receipt?
Use a reliable source suited to the transaction and document the reference time and conversion. The accounting method does not replace specific VAT valuation rules. Keep the invoiced amount and quantity actually received.
25. How do we reconcile an invoice and a payment net of fees?
Separate the receivable, gross payment, fees and any conversion. A difference may reflect company-borne fees, partial settlement or an agreed adjustment. Explain it rather than hiding it in revenue.
26. Who must receive electronic invoices from September 2026?
Receipt concerns VAT-taxable businesses established in France within the scheme, including those benefiting from the small-business VAT exemption. Check your transactions’ scope and choose a suitable approved platform. Specific operations can be excluded.
27. Who must issue electronic invoices in 2026 or 2027?
For in-scope transactions, mandatory issuance begins on 1 September 2026 for large and intermediate-sized businesses, then on 1 September 2027 for SMEs and microbusinesses. Assess data-reporting obligations alongside that timetable.
28. What if customers are abroad or are individuals?
These transactions may fall under e-reporting rather than domestic electronic invoicing. Treatment depends on the transaction and VAT regime; there is no single answer for every international flow. Also assess purchases from French suppliers.
Custody and access
29. How do we check a provider after the MiCA transition?
Check official AMF or ESMA registers for the contracting entity and relevant services. A former French DASP registration no longer establishes authorisation for every activity. Certain financial entities may operate through MiCA Article 60 notification.
30. What should be exported before closing an account?
Export purchases, sales, exchanges, deposits, withdrawals, fees, rewards and balance statements with available dates and identifiers. Keep original files outside the platform. Reconcile balances before and after migration.
31. Is a transfer between our wallets a sale?
Not where the same asset remains with the same owner and no additional transaction occurs. Fees still need tracking. A conversion, loan, bridge or change of rights may require a different analysis.
32. Who should access business accounts?
Define proportionate permissions and a recovery process supporting business continuity. Avoid a single person’s absence blocking the business. Do not share secrets with all employees: continuity and confidentiality must be designed together.
33. Should private keys be sent to the accountant?
No. Public addresses, exports and economic records support accounting work. Private keys, recovery phrases and login codes belong in your security arrangements. Any read-only access should be limited to the actual need.
Collateral, obligations and preparing records
34. Can crypto-assets be pledged as collateral?
French law provides a pledge regime whose practical rules were clarified by the decree of 29 May 2026, effective from 1 June 2026. Review the contract, authority, custody and risks. A lender remains free to reject proposed collateral.
35. Does collateral automatically create a sale?
A straightforward pledge without title transfer is not a sale on creation. Other structures may have different effects. Enforcement, asset lending and reuse require assessment of the terms and the holder’s regime.
36. What must be recorded for pledged assets?
Track quantities, values, the secured debt and availability restrictions. Prepare required disclosures under the year’s accounting framework. Keep the declaration, agreement and relevant custodian confirmations.
37. Can tokens replace salary payments?
Salary payment must respect the methods prescribed by French employment law. Additional token awards require a separate assessment of employment, social contribution and tax rules. Informal employee agreement does not settle those obligations.
38. How can an incomplete history be reconstructed?
Inventory accounts and available evidence, then reconcile platforms, bank records and blockchain data. Identify gaps and assumptions. Corrections are possible in some circumstances, but no method guarantees recovery of permanently lost data.
39. Can the accountant ask about the source of funds?
Yes. Professional due-diligence obligations require understanding the client, activity and transactions. An inability to meet those obligations can prevent an engagement. Prepare contracts, invoices and evidence explaining significant flows.
40. What should we prepare for a first meeting?
Describe the activity, legal form, tax regime, accounts and wallets, volumes, available exports and deadlines. Explain whether you need incorporation support, historical reconstruction, year-end work or ongoing accounting.
Explore a subject in more detail
- Our crypto accounting approach
- Holding companies and crypto treasury
- Mining and equipment
- Electronic invoicing and crypto payments
- Crypto service providers and MiCA
Official reference sources
- ANC — Regulations 2026-01 and 2026-02 (French)
- French Tax Code — Article 150 VH bis (French)
- French Tax Code — Article 1649 bis C (French)
- French tax administration — electronic invoicing (French)
- Decree of 29 May 2026 — crypto collateral (French)
- French Labour Code — salary payments (French)
Have a question about your company? Contact the firm with your activity and the issue you need to resolve.