This archive examines accounting under France's former PSAN regime. It is retained to explain the development of the framework and the distinction between a provider's own assets and assets held for clients. Current service permissions must be assessed under the applicable MiCA framework.
Registration and optional authorisation were different
The PACTE framework introduced PSAN requirements for certain digital-asset services. Mandatory registration and the former optional PSAN authorisation were distinct processes; the original text mixed some of their requirements.
The AMF was the relevant authority for the PSAN authorisation, with the competent authorities' roles determined by the framework. The original claim that the authorisation was issued by the ACPR was inaccurate. Société Générale-FORGE's authorisation was cited as a historical milestone, not proof that other providers had identical status.
Registration or authorisation should not be presented as a guarantee against loss, fraud or operational failure.
The transition to MiCA
MiCA established a European framework for crypto-asset service providers, called PSCA in French and CASP in English. The French transitional period for eligible former providers ended on 1 July 2026. It was not an additional rolling 18-month extension available to every applicant.
Check the exact entity, authorised services and cross-border arrangements. An announcement of an application or an old registration number is not equivalent to current permission. See the AMF's official lists.
Accounting for client custody
The central accounting question in the original article was whether the provider acts as an agent for client assets or must recognise assets and a corresponding restitution obligation.
The historical framework examined segregation and reconciliation, restrictions on using client assets, transaction approval controls and the means of returning the assets. The precise cumulative conditions must be read in the rules applicable to the period.
A provider's own trading position and a client's safeguarded balance must not be mixed merely because they use the same blockchain. The records should demonstrate ownership, quantities, restrictions and the provider's obligations.
What the original numerical example illustrated
The article used quantities of 400 and 600 tokens valued at €218, producing €87,200 and €130,800 respectively, to illustrate different custody-related disclosures. A later €210 price produced a €126,000 amount for 600 tokens.
These were examples within a particular accounting scenario. They are not sufficient by themselves to determine recognition, profit or tax. The contract, rights of use, return obligation and subsequent events need to be analysed together.
Evidence for the year-end file
- Reconcile client-level balances with technical custody records.
- Distinguish company holdings from client-related assets.
- Document who can authorise transactions and any permitted use of assets.
- Explain restrictions, restitution obligations and credit exposure.
- Support valuations and disclosures with a consistent method.
The ANC has since published Regulations 2026-01 and 2026-02. The first addresses crypto-assets generally; the second concerns the banking sector. Do not apply the banking-specific text to every ordinary company merely because it holds crypto. Official ANC regulations.
For current support, visit MiCA and CASP services.