ANC 2026-01: preparing for crypto-asset accounting changes
Published 17/03/2026 · 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.
Identify the text relevant to your entity
ANC Regulations 2026-01 and 2026-02, adopted on 9 January 2026, were endorsed by the order of 12 August 2026 published in the French Official Journal on 3 September. Regulation 2026-01 amends the French general accounting framework, while 2026-02 concerns banking institutions. CASP status alone does not determine an entity’s accounting framework.
The development addresses crypto-assets and similar items, including holdings, issuance, lending and services for clients. It builds on existing French accounting rules; it is not the first recognition of crypto-assets in company accounts.
Start with the rights attached to the asset
A token’s commercial label is not enough. The file should describe rights, obligations, counterparties and intended use. Assets marketed as “stablecoins” should not automatically receive identical treatment without assessing their classification.
- Securities, financial contracts and bons de caisse: article 619-8 refers to the rules corresponding to their characteristics.
- Electronic money tokens: article 619-8 provides for account 513 and separate year-end treatment.
- Rights to goods or services used in the business: article 619-9 applies the rules for those rights when both specified conditions are met.
- Other situations within article 619-10: recognition in account 522, including when the article 619-9 conditions are not met.
A treasury acquisition and a right to receive a service cannot be classified solely because both are called crypto-assets. Our company investment guide places classification within the management decision.
Distinguish preparation from first application
The timetable for Regulation 2026-01 is now confirmed: article 9 applies to accounts for financial years beginning on or after 1 January 2027. Early application is permitted for the financial year in progress when publication in the Official Journal occurred. Endorsement in September 2026 does not make the new rules compulsory for every company’s 2026 accounts.
Three different dates
- 9 January 2026: adoption by the ANC.
- 3 September 2026: publication of the endorsement order and regulations in the Official Journal.
- 1 January 2027: the opening-date threshold for mandatory application of Regulation 2026-01.
For a calendar-year company, the year beginning on 1 January 2027 falls within mandatory application. For a different reporting cycle, the opening date matters. Early application requires a review of methods, available records and transition effects; it is more than adding new account numbers.
Prepare first application
Keep an inventory of positions and evidence of the intention to use rights within the business. Article 9 provides a specific rule when that intention cannot be established retrospectively: determine it at the application date and reclassify in the opening balance sheet without changing the value. This targeted provision is not a general option to revalue assets freely.
Direct source: order of 12 August 2026 and annexed regulations. The ANC page provides the published and annotated versions.
Build an inventory useful for year-end reporting
Implementation connects contracts, operational statements and journal entries. For each position, assemble the asset, quantity, owner, custody location, rights, intended use and valuation sources. Separate proprietary assets, loans and borrowings from assets held for clients.
Year-end valuation and disposals are different events
For account 522 assets, article 619-12 provides for year-end market-value measurement, with differences recorded in temporary balance-sheet accounts 4742 or 4752. An unrealised loss requires examination of the provision specified in the text, taking applicable hedging provisions into account. A price increase is not automatically a realised disposal gain.
Article 619-15 provides for FIFO or weighted average cost for relevant fungible assets when calculating disposal results. Accounts 7674 and 6674 distinguish net disposal income and expense. The method must be reproducible from historical records, including after a platform or software migration.
Illustrative year-end file
Suppose a company holds an asset within account 522 acquired for €10,000 and valued at €12,000 at year-end. Its file should substantiate the quantity, acquisition cost and reliable source supporting €12,000, then apply the required unrealised-difference mechanism. Simply recording €2,000 of realised profit would not explain that treatment. A later disposal is a separate event, with the relevant balances reversed as appropriate.
Lending, borrowing and client transactions
Article 619-19 separately addresses the lender, borrower, restitution obligation and remuneration. Document the contract, counterparty risk and recovery conditions. Custody and transactions for clients require a different analysis under articles 629-1 onwards. Our CASP accounting guide explains the controls to prepare.
Prepare information for the notes
- Quantities and amounts held, with platforms or data sources and the valuation time convention.
- Asset categories, attached rights, cost methods and relevant impairment information.
- Positions lent, borrowed or pledged, and reasons for relevant reclassifications.
- For providers, information about assets held for clients and restitution obligations.
Frequently asked questions
Do all crypto-assets belong in account 522? No. Review their characteristics and the conditions in articles 619-8 to 619-10.
Can software perform the entire analysis? It can assist imports and reconciliations, but contracts, rights and accounting methods require documented assessment.
Does the ANC text also settle tax and MiCA authorisation? These need separate reviews. An accounting entry does not provide regulatory authorisation or replace tax analysis.