Cerfa 3916-bis: Declaring Foreign Crypto Accounts in France

This is the French crypto form people most often skip — and the one DGFiP now cross-checks hardest. The 3916-bis is not about gains at all; it declares the existence of a crypto account held with a provider established abroad, and it is the distinct counterpart to the 2086, which declares what you earned. Any French tax resident with an account on Binance, Coinbase, Kraken, Bitstamp, or any foreign platform files it every year, with no threshold and no exemption. From 1 January 2026, DAC8 hands the DGFiP the list of French accounts at EU-authorised CASPs, so an omission is now automatically detectable. This article walks the form box by box, covers the edge cases, and sets out how it sits alongside the 2086. The pillar is the France crypto tax guide.

Key points

• Who: any French tax resident who held, used, or closed a digital-asset account at a foreign provider.
• Threshold: none. A €10 balance triggers it (contrast Spain's Modelo 721 at €50,000).
• Self-custody is excluded, and so are French-authorised providers; only foreign third-party-hosted accounts count.
• It is independent of Form 2086: 3916-bis declares the account, 2086 declares the gains, and both can apply.
• Penalties (art. 1736 CGI): €750 per account (€1,500 if the balance exceeded €50,000 at any point); fraud brings an 80% surcharge and a 10-year reassessment.
• DAC8 (from 1 January 2026): CASPs report to the DGFiP, and 3916-bis becomes a cross-check point.

Who must file

The obligation rests on French tax residents who, during the year, held, used, or closed a digital-asset account opened with an entity established abroad (a foreign CASP / exchange — Binance Global, Coinbase outside France, Kraken outside France, Bitstamp, etc.). The French tax-residence test applies to the taxpayer, not the exchange.

Excluded:

• Self-custody wallets (MetaMask, Ledger hardware, Trust Wallet) — 3916-bis covers accounts hosted by a foreign third-party provider, not wallets you control directly.
• Accounts at French-authorised providers — the obligation targets foreign accounts.

So a French resident with a self-custodied Ledger and no foreign exchange account files no 3916-bis; one with any foreign exchange account does, regardless of how little is on it.

No threshold — the defining feature

Form 3916-bis has no de minimis threshold. It is filed as soon as a foreign digital-asset account has been held or used during the year, irrespective of balance or transaction volume. This is stricter than several EU equivalents — the Spanish Modelo 721 has a €50,000 threshold; France has none. A dormant foreign account with €10 on it is reportable.

This is the single most common French compliance failure: assuming a small or unused foreign account is below "some threshold." There is no threshold.

Independent of Form 2086

3916-bis and Form 2086 are independent and both can be required:

Examples:

• Unused Binance account in 2025, no disposals → 3916-bis only.
• Sold crypto from a foreign platform → 3916-bis + 2086 (gains computed under 150 VH bis).
• Self-custody only, sold to fiat via a French-authorised provider → possibly 2086 only (no foreign account).

Box-by-box (what the form captures)

Without reproducing the official form, 3916-bis is organised as:

1. Account holder identification — taxpayer details (pre-filled in the online return).
2. Account designation — the provider's name and the account identifier.
3. Provider details — name and address of the foreign entity hosting the account.
4. Account characteristics — opening date; closure date if applicable; whether held/used/closed during the year.
5. One block per account — a separate declaration for each foreign account (no aggregation across providers).

The data burden is one complete block per foreign account, including accounts closed during the year.

Penalties and the reassessment period

Under article 1736 X CGI:

The reassessment period (délai de reprise) is normally 3 years but extends to 10 years where the omission involves a non-cooperative state or characterised fraud (article L. 169 LPF). DGFiP enforcement has tightened where omissions are revealed by cross-checking external data — which is exactly what DAC8 industrialises.

DAC8 and 3916-bis from 2026

DAC8 does not remove the 3916-bis obligation. From 1 January 2026, EU-authorised CASPs automatically report French residents' accounts to the DGFiP. The taxpayer's own 3916-bis declaration still stands. The practical shift: 3916-bis becomes a cross-check point. A CASP-reported account with no matching 3916-bis is an obvious flag, and the first reconciliation follows the first DAC8 authority exchange (by 30 September 2027 for FY 2026 — see DAC8 impact on individuals and DAC8 vs CARF).

For a resident with prior unreported foreign accounts, the window to regularise before the first DAC8 cross-check is finite — this is the France-specific version of the voluntary-disclosure point.

Practical workflow

1. Inventory every foreign account held/used/closed in the year (including closed and near-empty ones).
2. Exclude self-custody and French-authorised providers; include all foreign third-party accounts.
3. File one 3916-bis block per foreign account with the annual return — no threshold to clear.
4. File Form 2086 separately if there were taxable disposals.
5. Reconcile against DAC8-reported data; regularise prior omissions before the first cross-check.

Using a tool to build the 3916-bis account list

The 3916-bis is a completeness problem, not a calculation: the risk is a single foreign account left off the list. A tool helps only if it surfaces every one of them. Confirm it:

• flags every foreign third-party-hosted account with no threshold filter, including small and dormant ones (a tool that hides low-balance accounts causes exactly the omission that is penalised);
• includes accounts closed during the year, which still have to be declared;
• keeps self-custody wallets (MetaMask, Ledger hardware, Trust Wallet) out of the 3916-bis list;
• distinguishes foreign providers from French-authorised ones, since only foreign accounts are reportable.

Waltio is French-market-specialised and Koinly supports the French regime; both can list connected accounts. No tool decides tax residence, which is the governing test and a question for a French adviser.

How Wag3s fits in

Wag3s Folio inventories connected accounts and flags every foreign third-party-hosted account for the 3916-bis with no threshold filter, separates self-custody, and reconciles the list against DAC8-reported activity so a CASP-reported account always has a matching declaration. Tax residence and any prior-omission regularisation are legal questions; Folio assembles the complete account list to support a qualified French tax adviser or expert-comptable on them, rather than resolving them itself.

Further reading

• France Crypto Tax Guide 2026 — the French pillar
• Cerfa 2086 Explained
• Crypto Capital Gains Calculation France (150 VH bis)
• The France €305 Exemption
• Spain Crypto Tax Guide 2026 — Modelo 721 comparison (has a €50,000 threshold)
• DAC8 Impact on Individuals
• DAC8 vs CARF Difference

Sources

• Légifrance — Article 1649 bis C CGI: the obligation to declare digital-asset accounts opened, held, used, or closed with entities established abroad.
• Légifrance — Article 1736 CGI: the €750-per-account fine, raised to €1,500 where the account value exceeded €50,000 at any point in the year.
• Légifrance — Article L. 169 LPF: the reassessment period extended to ten years where the article 1649 bis C declaration obligation is not met.
• impots.gouv.fr — Cerfa 3916 / 3916-bis : déclaration par un résident d'un compte ouvert, détenu, utilisé ou clos à l'étranger.
• Council Directive (EU) 2023/2226 (DAC8) — EUR-Lex.