CASPs: preparing accounts and ANC developments
Published 16/04/2026 · Updated 08/09/2026 · Houssen Issouf Aly, French chartered accountant
Crypto-assets · Companies · Directors
Practical guidance for companies and directors. Revised on 7 September 2026.
Distinguish two workstreams
Authorisation to provide crypto-asset services and accounting requirements address different questions. Following the end of France’s MiCA transition in July 2026, an old PSAN registration no longer establishes the right to continue operating. Check the entity, services and current status in official registers.
The framework provides for CASP authorisation and, for certain eligible financial entities, an article 60 notification deemed complete by the competent authority. A brand name, pending application or historical status does not replace verification. The AMF explains these routes.
Map services and transaction flows
Accounting needs to reflect the services actually provided: custody, exchange, order execution or other activities. For each customer journey, describe who receives funds or assets, executes transactions, holds assets, bills the customer and owes restitution. Separate proprietary transactions from those carried out for clients.
This map connects contracts, operational systems and accounts. It should also identify technical providers and group entities involved. A single user interface can conceal several contractual relationships and obligations.
Accounting and regulatory review
An accounting engagement helps produce explainable records and reconciliations. It does not grant MiCA authorisation. Statutory audit, regulatory controls and legal assistance need separately defined scopes based on the entity’s situation; not every CASP should be described as requiring identical engagements.
Accounting rules existed before 2026
ANC Regulation 2026-01 develops the French general accounting framework and builds on earlier rules, including Regulation 2018-07. Regulation 2026-02 concerns banking institutions, not every CASP solely because of that status.
Custody: document three conditions
Article 629-1 of the endorsed text governs the treatment of assets held for clients. Agency treatment without recognising those assets on the provider’s balance sheet requires conditions covering:
- Segregation: separation of client and proprietary assets within the recording system, with permanent agreement between quantities held and the technical custody records.
- Use and approvals: no use of client assets or associated rights without express consent, with multiple approvals for transaction decisions at the provider.
- Restitution: arrangements needed to return the assets held.
If a condition is not met, the text provides for asset recognition with an equal restitution liability and the corresponding subsequent measurement rules. An accounting presentation should not, by itself, determine the organisation’s regulatory compliance.
Revenue: explain the provider’s remuneration
For client transactions specified in article 629-2, only the provider’s remuneration enters profit or loss. Client trading volume does not automatically become the provider’s revenue. Proprietary activity and other services require their own assessment.
Illustrative example: a statement shows €100,000 of transactions executed for clients and €500 of commissions. Controls should trace the €500 billed, receipts, credits and outstanding balances, then explain the client-flow treatment. Recording €100,000 as provider revenue would not establish that analysis.
Closing and disclosures
Prepare quantities and values of assets held in custody, valuation sources, relevant commitments and recognised restitution liabilities. Articles 838-15 and 838-16 specify information according to the entity’s role. Proprietary assets also require the holding analysis described in our ANC 2026 guide.
Prepare records without assuming an effective date
Regulations 2026-01 and 2026-02 were endorsed by the order of 12 August 2026, published in the Official Journal on 3 September. For Regulation 2026-01, article 9 provides for financial years beginning on or after 1 January 2027, with early application permitted for the financial year in progress at publication. This accounting timetable is separate from the MiCA transition deadline.
Build a usable audit trail
- Common references: align client, entity, asset and account identifiers across tools.
- Quantity controls: compare client records, wallets and third-party statements, explaining transactions in transit and discrepancies.
- Revenue controls: connect the pricing agreement, transaction, commission, invoice or statement and receipt.
- Closing: substantiate balances, methods and adjustments with dated supporting records.
- Review: assign each discrepancy to an owner, retain the explanation and verify resolution.
Exports should remain usable after a software or provider change. A useful dashboard distinguishes amounts handled for clients from provider revenue, expenses and proprietary cash. The same controls should be reproducible each period.
Frequently asked questions
Does a separate wallet prove all custody conditions? No. Use, approval, quantity agreement and restitution arrangements also need documentation.
Are client assets always off balance sheet? Treatment depends on the text’s conditions and the actual arrangements. The word “custody” in a contract is insufficient.
What should we prepare for the accountant? Regulatory status, service list, client and subcontractor contracts, flow map, sample exports, chart of accounts, recent reconciliations and unresolved discrepancies.
Read the endorsed regulations and explore our support for crypto service providers.