Crypto Company Tax Audit in France

A company is not audited like an individual crypto holder. There is no €305 test and no 150 VH bis here — there is a vérification de comptabilité, a FEC demand, and from 2026 a DAC8 cross-check. This guide is what a company-side crypto audit actually examines and how the exposure differs.

TL;DR

• A company faces a vérification de comptabilité (the accounting is examined), not the individual control.
• The FEC is demanded under LPF article L47 A; it is tested against on-chain reality (see the crypto FEC).
• Reassessment window: 3 years general, 10 years for undeclared foreign accounts/activity.
• From 2026 the DGFiP cross-checks against DAC8 (Directive (EU) 2023/2226) reported data.
• The individual regime (150 VH bis, €305) does not apply — a company's crypto is corporate accounting + corporate tax.
• The recurring finding: a format-valid FEC that does not reconcile to the chain.

It is the accounting that is examined

For an individual occasional investor, a control looks at the income declaration (see DGFiP crypto audit for that path). For a company, the procedure is a vérification de comptabilité: the administration examines the accounting records themselves. It can require the FEC under LPF article L47 A and test it. The individual-specific mechanics — the 150 VH bis portfolio method, the €305 exemption — are irrelevant to a company; corporate crypto is corporate accounting under the ANC/PCG rules and corporate tax.

The reassessment window

A crypto company with undisclosed foreign-exchange or custodial accounts is exposed to the ten-year window — and from 2026 the DGFiP has the DAC8 data to find the gap. The extended window plus automatic reporting is the company-side risk, not a one-year spot check.

What the DGFiP examines

In a crypto vérification the focus areas are:

• FEC reconcilability to on-chain activity (the central test);
• completeness of the wallet/account inventory;
• valuation and accounting policy under the ANC/PCG rules;
• characterisation of activity (holding vs trading vs digital-asset services) and its corporate-tax treatment;
• reward income (staking/mining/etc.) recognition;
• cross-border and inter-company flows.

The recurring finding is a FEC that passes the format validator but does not reconcile to the chain — missing wallets, unexplained transfers, undocumented valuations (see the reliable audit trail).

DAC8 as the 2026 cross-check

From 2026 the DGFiP receives crypto-asset service-provider data under DAC8 (Directive (EU) 2023/2226). For a company this is a reconciliation cross-check: reported platform activity vs the company's books and FEC. A material unexplained gap is a trigger. The defensive posture is a documented reconciliation to DAC8-reported data performed before an audit, not improvised during one (see DAC8 for accounting firms).

Prior unreported years

Given the ten-year window and DAC8 detection from 2026, prior unreported company years are a counsel-led regularisation question, not a self-fix. A voluntary, documented correction ahead of the first DAC8 cross-check generally yields a materially better outcome than a discovered omission. This is tax-counsel/expert-comptable territory.

Practical guidance

1. Maintain a complete wallet/account inventory mapped to the books.
2. Keep the FEC reconciled to on-chain balances continuously, not at notice.
3. Document the ANC/PCG valuation and accounting policy and the activity characterisation.
4. Reconcile the books to DAC8-reported data each year from 2026.
5. Regularise prior years with counsel given the ten-year window.
6. Treat reconcilability as the deliverable — format validity alone does not survive a vérification.

How vendor tools support a company audit

Cryptio and Request Finance maintain the wallet inventory, the ANC/PCG-mapped ledger, the FEC, and reconciliation evidence a vérificateur tests. Confirm the tool produces a FEC that reconciles to on-chain balances and supports a DAC8 reconciliation — the audit tests reconcilability, so that is the capability that matters.

How Wag3s helps

Wag3s Ledger keeps the company's wallet inventory, ANC/PCG-mapped ledger and FEC continuously reconciled to on-chain activity, and produces the DAC8 reconciliation — so a vérification de comptabilité meets a defensible, pre-built file rather than a reconstruction. See the Ledger product page and the Wag3s for accountants page.

Further reading

• The FEC for Crypto in France
• French GAAP for Crypto: The ANC Rules
• Crypto Audit Trail and Piste d'Audit Fiable
• DGFiP Crypto Tax Audit (individual)
• DAC8 for Accounting Firms
• Crypto Audit Readiness

Sources

• LPF article L47 A — FEC required in a vérification de comptabilité — Légifrance
• Reassessment windows: 3-year general right; 10-year extended right for undeclared foreign accounts/activity
• Council Directive (EU) 2023/2226 (DAC8) — CASP data to tax administrations from 2026 — EUR-Lex
• Corporate crypto follows the ANC/PCG accounting rules and corporate tax — the individual 150 VH bis / €305 regime does not apply