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 article is specifically the company-side procedure — what a corporate crypto audit examines and how the exposure differs from the individual case. The individual path is the DGFiP audit; the document at the centre is the crypto FEC, and its enforcement is the reliable audit trail.

How a company audit differs

• A company faces a vérification de comptabilité — the accounting itself is examined — not the individual income control.
• The FEC is demanded under LPF article L47 A and tested against on-chain reality.
• The reassessment window is three years generally, ten for undeclared foreign accounts or activity.
• From 2026 the DGFiP cross-checks against DAC8 (Directive (EU) 2023/2226) reported data.
• The individual regime (150 VH bis, the €305 test) does not apply: a company's crypto is corporate accounting plus corporate tax.
• The recurring finding is 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.

What Triggers a Crypto Company Audit in France

The DGFiP does not publish a selection algorithm, but the observable triggers for crypto-company vérifications follow a pattern:

Activity scale and sector signals: Companies operating in digital-asset services — trading, custody, DeFi protocol operation, token issuance, NFT platforms — are higher-probability audit subjects than companies that happen to hold a small treasury position. Sector-level intelligence informs DGFiP selection, particularly post-2026 with DAC8 data flowing.

CASP-reported data gaps: From 2026, the DGFiP receives aggregate transaction data from CASPs. A company whose filed accounts show zero or minimal crypto activity while the CASP data shows material volumes is an automatic flag. This is the specific risk that the new reporting environment introduces for companies that have understated or omitted crypto activity.

FEC format errors and inconsistency: The FEC is submitted digitally and format-validated immediately. A company whose FEC fails format validation, or whose FEC shows internal inconsistencies (accounts that don't balance, periods that don't close), is a signal. But a format-valid FEC that an auditor then cross-references against on-chain activity and finds unexplained gaps is a worse position — the company passed the automated check and failed the substantive one.

High-value transactions and foreign accounts: Large on-chain transactions — particularly to or from foreign CASPs, DeFi protocols, or unhosted wallets — and undisclosed foreign custodial accounts generate both flag risk and the ten-year-window exposure under the foreign-account declaration rules.

The ANC/PCG Accounting Framework for Companies

French companies account for crypto assets under the Autorité des Normes Comptables (ANC) rules, applied through the Plan Comptable Général (PCG). The key points a vérificateur tests:

• Classification: Crypto held as a financial asset vs. inventory vs. other classification depends on the company's activity. A company trading crypto commercially classifies holdings differently from a company holding bitcoin as a treasury reserve. The classification must be documented and consistently applied.
• Valuation at closing: Under French GAAP, the lower of cost or market value rule (prudence principle) applies. Unrealized losses must be provisioned; unrealized gains are not recognized. This is the opposite of some IFRS treatments and a common source of error when non-French-trained accountants apply the framework.
• Staking and mining income: Recognized at fair value when received (as income, not a capital-gain event), with the subsequent disposal giving rise to a realized gain or loss measured from the recognition value.
• Gas fees: Treated as an expense, not capitalized into the asset's cost basis.

A vérificateur expects the company to present a documented accounting policy covering each of these points, consistent across years. An undocumented ad hoc classification is a finding.

Where a tool supports a company audit

Cryptio and Request Finance maintain the wallet inventory, the ANC/PCG-mapped ledger, the FEC, and the 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.

Where Wag3s fits

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. The accounting-policy judgement and any prior-year regularisation are an expert-comptable or tax-counsel matter; Wag3s supplies the reconciled records and the FEC that defence is built on. 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

• Légifrance — Article L47 A LPF: the FEC required in a vérification de comptabilité.
• Légifrance — Article L. 169 LPF: the three-year general reassessment right, extended to ten years for undeclared foreign accounts or activity.
• BOFiP — Contrôle des comptabilités informatisées : remise du FEC (BOI-CF-IOR-60-40-10): the administration's examination of computerised accounting.
• Council Directive (EU) 2023/2226 (DAC8) — EUR-Lex: CASP data to tax administrations from 2026.
• Corporate crypto follows the ANC/PCG accounting rules and corporate tax — the individual 150 VH bis / €305 regime does not apply.