Crypto Law Profile

PACTE Digital Asset Service Provider Regime

France’s PACTE Law created the AMF DASP/PSAN regime for custody, exchange, trading-platform and related digital asset services. It is now repealed for authorisation purposes and replaced by MiCA CASP authorisation from July 1, 2026.

France Repealed Act May 24, 2019

At a glance

Status Repealed from July 1, 2026 and replaced by MiCA CASP authorisation.
Regulators AMF administered DASP registration; ACPR reviewed AML/CFT elements.
Core Services Covered custody, fiat exchange, crypto exchange and trading platforms.
Successor Regime MiCA CASP authorisation is the operative post-transition framework.

Overview

France’s PACTE Digital Asset Service Provider regime was the national framework created by Law No. 2019-486 of 22 May 2019 for prestataires de services sur actifs numériques, commonly abbreviated PSAN in French and DASP in English. The regime was administered by the Autorité des marchés financiers (AMF), with the Autorité de contrôle prudentiel et de résolution (ACPR) involved in AML/CFT review. As of 6 July 2026, the regime should be treated as a repealed historical framework for service-provider authorisation: the French transition to the EU Markets in Crypto-Assets Regulation ended on 1 July 2026, and MiCA authorisation is now the operative route for crypto-asset service providers in France.

PACTE DASP regime scope

Article 86 of the PACTE Law inserted a dedicated chapter into the Monetary and Financial Code for digital asset service providers. The original service perimeter covered custody of digital assets or access to digital assets for third parties, buying or selling digital assets for legal tender, exchanging digital assets for other digital assets, operating a digital asset trading platform, and ancillary activities such as order reception and transmission, portfolio management, advice, underwriting and placement of digital assets.

The regime sat alongside PACTE’s separate optional visa framework for token offerings. For this profile, the relevant subject is the intermediary framework for firms providing digital asset services in or into France, rather than the ICO visa itself.

Registration, optional licensing and supervisory checks

The PACTE framework used a two-tier design. Certain core services were subject to mandatory AMF registration before the provider could operate in France. The AMF described the mandatory registration perimeter as custody, buying or selling digital assets for legal tender, exchanging digital assets for other digital assets, and operating a digital asset trading platform. Registration checks included fit-and-proper review of managers and beneficial owners, and AML/CFT review for relevant services in coordination with the ACPR.

France also provided optional licensing for DASPs established in France. Licensed DASPs had to meet broader organisational, financial-resource and conduct requirements, including resilient IT systems, internal control, conflict-of-interest arrangements, complaint handling, client information, client agreements and service-specific requirements. This optional license did not create an EU passport under the national PACTE regime.

Enhanced registration and MiCA transition

The French framework evolved before it was replaced. The AMF updated its rules in 2023 to reflect an enhanced registration regime introduced by the DDADUE Law. Those changes applied from 1 January 2024 for new players seeking to provide the four services subject to mandatory registration and aligned parts of the DASP license with the forthcoming MiCA CASP authorisation pathway.

MiCA changed the legal baseline. The AMF stated that the harmonised EU framework would replace national frameworks from 30 December 2024 for providers not entitled to a transitional period. Existing French DASPs with simple registration, enhanced registration, optional licensing, or certain fifth-category services before 30 December 2024 could continue only for the French market during the transition, with the transition ending on 30 June 2026 and MiCA authorisation required from 1 July 2026.

Status and editorial treatment

For CryptoSlate taxonomy purposes, the PACTE DASP regime should be marked as Repealed. The status is supported by Ordonnance No. 2024-936, which abrogated the prior Monetary and Financial Code provisions for digital asset services with effect from 1 July 2026, and by the AMF’s statement that only MiCA-authorised CASPs could provide crypto-asset services in France from that date. The profile remains useful as a historical reference because PACTE shaped France’s pre-MiCA registration model and the transition path for registered or licensed DASPs.

Key provisions

Digital asset service perimeter

Defined DASP services including custody, fiat purchase/sale, crypto exchange, trading platforms, advice, portfolio management and placement.

Scope May 24, 2019 Source

Mandatory AMF registration

Required registration for core services such as custody, fiat exchange, crypto exchange and trading-platform operation in France.

Registration May 24, 2019 Source

AML/CFT and fit-and-proper checks

AMF and ACPR checks covered managers, beneficial owners and AML/CFT systems for relevant registered DASP services.

AML/CFT May 24, 2019 Source

Optional DASP licensing

France offered optional AMF licensing with broader organisational, financial-resource, IT, conduct and service-specific obligations.

Licensing May 24, 2019 Source

Enhanced registration

From Jan. 1, 2024, enhanced registration applied to new players seeking the four services subject to mandatory registration.

Registration Jan 1, 2024 Source

MiCA replacement

The national DASP transition ended July 1, 2026; only MiCA-authorised CASPs may provide crypto-asset services in France after that date.

Transition Jul 1, 2026 Source

Timeline

  1. PACTE Law published

    Law No. 2019-486 was published in the Journal officiel, including Article 86 on digital asset service providers.

    Enacted Source
  2. DASP service perimeter in force

    Monetary and Financial Code Article L.54-10-2 entered into force for digital asset services under PACTE.

    In force Source
  3. AMF enhanced-registration policy

    AMF amended its General Regulation and DASP policy to reflect enhanced registration and prepare for MiCA.

    Enacted Source
  4. Enhanced registration applies

    Enhanced DASP registration became mandatory for new players seeking the four services subject to mandatory registration.

    In force Source
  5. MiCA CASP regime applies

    MiCA became applicable to crypto-asset services, replacing national frameworks for providers without transition rights.

    Partially effective Source
  6. PACTE DASP transition ends

    French DASP transition ended; providers needed MiCA CASP authorisation to continue crypto-asset services in France.

    Repealed Source

Who it affects

Actors

Autorité de contrôle prudentiel et de résolution, Autorité des marchés financiers, European Securities and Markets Authority

Asset classes

Crypto assets, Digital assets, Tokens

Official sources

Editorial note

Updated July 6, 2026: status reflects Ordonnance n° 2024-936 and AMF notices stating that the PACTE DASP transition ended on July 1, 2026.