France PACTE Initial Coin Offering Visa Regime

France’s PACTE Initial Coin Offering Visa Regime was a national, optional approval framework created by Article 85 of Loi n° 2019-486 of 22 May 2019. The regime inserted former Articles L.552-1 to L.552-7 into the French Monetary and Financial Code and let token issuers seek an Autorité des marchés financiers (AMF) visa before a public token offering. It was aimed at token offerings outside existing financial-instrument regimes, mainly utility token ICOs. As of 3 June 2026, the PACTE ICO visa is historical: former Articles L.552-4 to L.552-7 were abrogated in connection with France’s MiCA adaptation, and current French rules route offers and admissions of non-ART/non-EMT crypto-assets through MiCA Title II notifications to the AMF.

What the PACTE ICO visa covered

The regime applied to issuers carrying out a public offer of tokens and choosing to request an AMF visa. Former Article L.552-2 defined a token as an intangible asset representing one or more rights in digital form that could be issued, registered, stored or transferred using distributed ledger technology. Former Article L.552-3 treated a public token offer as any proposal to the public to subscribe for those tokens, while excluding offers to a limited number of persons set by AMF rules. AMF materials described the eligible category as digital assets not classified as financial instruments.

The visa was not mandatory. The AMF stated during the PACTE rollout that fundraising without an AMF visa would remain legal in France, but issuers without a visa could not use general solicitation. The AMF announced the first optional ICO approval on 19 December 2019 and described eligible offerings as public offerings of utility tokens that were not treated as financial instruments.

Key provisions of the optional visa process

• Issuer status: the issuer had to be a legal entity established or registered in France.
• Information document: the issuer had to prepare a document giving useful information on the offer and issuer; promotional communications had to be accurate, clear and not misleading.
• Safeguarding: the issuer had to maintain arrangements for monitoring and safeguarding funds and digital assets raised during the offer.
• AML/CFT: AMF materials identified compliance with anti-money laundering and counter-terrorist financing rules as a condition of the visa process.
• AMF powers: the AMF could order communications referring to a visa to stop and withdraw the visa if the offer no longer matched the information document or guarantees.

The AMF visa was framed as a review of minimum statutory guarantees and of whether the information document was complete and understandable. It was not an endorsement of the commercial merits of the project, did not authenticate the financial, accounting or technical information presented, and did not include AMF verification of smart contracts linked to the offering. The former framework also required subscribers to be informed of the offer results and, where relevant, of the organisation of a secondary market.

Status and MiCA transition

For current offers by persons with a French home member-state nexus, AMF guidance now describes a MiCA white-paper notification pathway. The AMF states that offerors of crypto-assets other than asset-referenced tokens or e-money tokens, persons seeking admission to trading and platform operators must notify a white paper to the AMF, with supporting classification explanations and host-state information, at least 20 working days before publication. This profile is a legal-reference summary and does not provide legal, tax, investment or compliance advice.