The FEC for Crypto in France

A French company gets no crypto exemption from the Fichier des Écritures Comptables. In a tax audit it must hand over a standardised file of its accounting entries, on demand, in a fixed format. This article is narrowly about that file: its legal basis, why on-chain data is not a FEC, and how crypto activity actually maps into it. It is the document at the centre of the company tax audit, rests on the French GAAP / ANC rules, and is enforced in practice by the reliable audit trail.

What the FEC requires

• The legal basis is LPF article L47 A: the administration can require the FEC in a vérification de comptabilité.
• The format is fixed by LPF article A47 A-1, the standard introduced by the arrêté of 29 July 2013 — 18 mandatory fields in a fixed order.
• It is one file per fiscal year, covering all journals, in chronological order of validation.
• On-chain data is not a FEC: an explorer or wallet export is the source, not double-entry PCG entries carrying the A47 A-1 fields.
• Crypto maps in via the ANC/PCG rules — a statutory basis, distinct from IAS 38 or ASU 2023-08.
• The objective is reconcilability to on-chain reality, not just format validity.

The legal basis, precisely

The FEC is not a best-practice convention; it is a statutory obligation. Its basis is LPF article L47 A: in a vérification de comptabilité, a taxpayer keeping computerised accounts must provide the administration a copy of the accounting records in a dematerialised form. The form and content are fixed by LPF article A47 A-1, the standard introduced by the arrêté of 29 July 2013.

Concretely, the FEC is a single file for the fiscal year, containing the entries of all accounting journals, in chronological order of validation, including after-inventory entries and excluding centralisation and the closing of income and expense accounts. It has 18 mandatory fields in a fixed order (journal, entry number/date, account, piece reference/date, label, debit, credit, lettrage, validation date, and the rest as specified). The authoritative field list is the A47 A-1 specification — you reference it; you do not reconstruct it from memory.

Why on-chain data is not a FEC

The most common error in a crypto company is treating a blockchain explorer export or a wallet/exchange CSV as accounting. It is not. That data is the source; the FEC is the double-entry accounting record built from it — journalised to PCG accounts, valued in fiat, with piece references and validation dates, in the A47 A-1 structure.

Handing an explorer export to a vérificateur and calling it the accounting fails the obligation.

How crypto activity maps into the FEC

Every economic event must be journalised to PCG accounts under the ANC rules (Règlement ANC 2018-07 and successors), then expressed as compliant FEC lines:

• Acquisition / disposal — cost and proceeds journalised; the disposal result computed on the statutory (French-GAAP) basis.
• Fees — network and platform fees as charges or as part of cost, per policy.
• Reward receipt (staking/mining/airdrop) — recognised per the ANC/tax characterisation, valued in fiat at receipt.
• Transfers between own wallets — not a disposal; an internal movement that must still reconcile.

The mapping is the accounting judgement; the FEC is its standardised output. The statutory carrying basis is French GAAP, distinct from any IFRS or US-GAAP set (see IAS 38 and crypto and ASU 2023-08).

The real risk: a valid FEC that does not reconcile

A FEC can be format-valid and still fail an audit if it does not reconcile to on-chain reality — missing wallets, unexplained transfers, valuations that do not tie to a defensible source. For a crypto company the vérificateur will test the FEC against the chain. The objective is therefore reconcilability, not just passing the format validator, and it connects directly to the reliable audit trail and the company tax audit.

Practical guidance

1. Treat the FEC as mandatory — crypto activity does not exempt it (LPF L47 A).
2. Build it from journalised PCG entries, not from explorer exports.
3. Reference the A47 A-1 specification for the 18 fields and order — do not improvise the format.
4. Map every event type (acquire/dispose/fee/reward/internal transfer) to PCG accounts under the ANC rules.
5. Reconcile the FEC to on-chain balances before any audit — completeness of wallets first.
6. Keep the valuation source documented per entry (the audit trail).

Where a tool helps produce a crypto FEC

Cryptio and Request Finance map on-chain activity to a French chart of accounts and export FEC-compatible records. Confirm the tool outputs the A47 A-1 18-field structure, journalises to PCG accounts under the ANC rules (not an IFRS export relabelled), and supports a wallet-completeness reconciliation; a FEC that does not reconcile to the chain is the real exposure.

Where Wag3s fits

Wag3s Ledger journalises crypto activity to PCG accounts under the ANC rules, produces the A47 A-1-structured FEC, and reconciles it to on-chain balances across wallets and chains so the file is not merely format-valid but defensible in a vérification de comptabilité. The accounting judgement behind the mapping (classification, valuation policy, activity characterisation) is an expert-comptable's; Wag3s produces and reconciles the file that judgement is expressed in. See the Ledger product page and the Wag3s for accountants page.

Further reading

• French GAAP for Crypto: The ANC Rules
• Crypto Company Tax Audit (France)
• Crypto Audit Trail and Piste d'Audit Fiable
• Crypto Audit Readiness
• Multi-Chain Reconciliation
• BOFiP Crypto References 2026

Sources

• Légifrance — Article L47 A LPF: the obligation to hand over a copy of the computerised accounting records in a vérification de comptabilité.
• Légifrance — Article A47 A-1 LPF: the form and content of the FEC (18 mandatory fields), the standard set by the arrêté of 29 July 2013.
• impots.gouv.fr — Fichiers standards des écritures comptables (art. L. 47 A-1 du LPF): the official format specification.
• BOFiP — Contrôle des comptabilités informatisées : remise du FEC (BOI-CF-IOR-60-40-10): the administration's practice on the FEC.
• Crypto-to-PCG mapping follows the ANC rules (Règlement ANC 2018-07 and successors).