The transition from France's former PSAN regime to crypto-asset service provider authorisation under MiCA is a significant change for service businesses. It connects the commercial offering with authorised activities, a documented operating model and appropriate resources. PSCA is the French term; CASP is the English equivalent.
What ended on 1 July 2026
The transitional period allowing certain existing providers to continue services in France without MiCA authorisation ended on 1 July 2026. A former PSAN registration is therefore no longer sufficient by itself for the relevant services. An application and an authorisation are different things. AMF reminder dated 5 February 2026.
MiCA addresses services provided professionally to clients. Holding bitcoin in a company's own treasury does not automatically make that company a CASP. Its actual activities, transactions, customers and contracts must be examined. AMF explanation of MiCA's scope.
A documented operating model
For an affected provider, the work goes beyond submitting an administrative file. Who makes decisions? Who controls access? How are complaints, incidents and conflicts handled? Which functions are outsourced? How would operations continue if an essential supplier became unavailable?
The answers must fit the company's size, services and risks. A generic procedure copied from another business does not demonstrate an effective control.
The financial consequences
Compliance requires management attention, skills, tools and oversight. A budget should cover recurring costs, staffing changes and reliance on external providers, then compare those commitments with expected income and available cash.
Authorisation does not guarantee profitability or eliminate risk. Equally, having written procedures does not mean every proposed service is authorised. The permission's scope and the conditions of operation must be checked.
Three possible business paths
- Provide regulated services directly. This requires appropriate authorisation, resources and operational implementation.
- Work with an authorised provider. Responsibilities, contracts and boundaries need to be defined. A partnership does not automatically cover every activity of the partner.
- Change or discontinue services. A transition must address clients, assets, data, contracts and remaining obligations.
These are analytical options, not a certain prediction of how the market will develop. Calling every crypto business a financial institution is also too broad: legal and prudential classifications depend on status and activities.
Accounting and management information
The firm can help map transactions, distinguish company assets from client-related operations, reconcile records and prepare financial reporting. The accounting file should explain revenue, commissions, liabilities and positions with appropriate supporting evidence.
Accounting preparation does not amount to regulatory approval or a promise of authorisation. Legal advice, specialist compliance work and the accountant's assignment should be coordinated and defined in their respective engagements.
Before selecting a partner
Check the exact legal entity, website domain and authorised services in official registers. Do not rely solely on a logo, an announcement of an application or a former PSAN number. AMF authorised-provider lists.