PSAN to CASP: The France MiCA Migration

France regulated crypto before the EU did. Its national PSAN regime, created by the 2019 PACTE law, now has to give way to MiCA's EU-wide CASP authorization on a fixed clock: the French transitional period ends 1 July 2026, and a provider that operates past it without a granted CASP authorization faces criminal exposure, not just a supervisory letter. This is the France-specific migration spoke — the timeline, the AMF process, and the conversion mechanics. For where this national deadline sits inside the wider MiCA phasing, see the MiCA timeline.

The migration in brief

• PSAN = French national regime (PACTE law, 2019). CASP = EU-wide MiCA authorization that replaces it.
• Hard deadline: 1 July 2026. After that date, no granted CASP authorization → must cease crypto-asset services in France.
• The deadline aligns with the EU-wide 18-month maximum transitional period.
• Criminal exposure for operating past the deadline without authorization: reported as up to two years' imprisonment and a €30,000 fine.
• AMF has accepted CASP applications since 1 July 2024; fast-track timelines run several months — a provider not yet in process is at timeline risk.
• CASP authorization is passportable across the EU/EEA — the upside of the migration.

PSAN vs CASP — what actually changes

The migration is a regime replacement, not an add-on. A PSAN registration does not automatically convert — the provider must apply for and obtain CASP authorization.

The timeline

• 2019 — PACTE law creates the PSAN regime.
• 30 June 2024 — MiCA's stablecoin titles (ART/EMT) apply.
• 1 July 2024 — AMF begins accepting MiCA CASP authorization applications (with pre-examination ahead of the regime's application).
• 30 December 2024 — the MiCA CASP regime applies; the transitional period for existing PSAN providers begins to run.
• Throughout 2025–2026 — transitional period: PSAN providers may continue under the national regime.
• 1 July 2026 — transitional period ends. Providers without a granted CASP authorization must cease crypto-asset services in France.

The "or until granted/refused" clause matters: a provider whose CASP application is refused before 1 July 2026 must stop at the point of refusal, not on 1 July. The deadline is a ceiling, not a guaranteed runway.

The criminal exposure

This is the part that distinguishes the PSAN-to-CASP migration from a routine licensing update. Operating crypto-asset services in France after 1 July 2026 without a granted MiCA CASP authorization is reported to carry criminal liability — up to two years' imprisonment and a €30,000 fine.

This reframes the risk calculus for any provider still weighing whether to apply. It is not an administrative late-fee situation. A provider that misses the deadline and continues operating is exposed to penal consequences, not just supervisory ones. Confirm the exact current penal provisions with French counsel — but plan on the basis that there is no soft landing.

The AMF process and timeline risk

The AMF has accepted CASP applications since 1 July 2024. Reported indicative fast-track timelines:

• Enhanced DASP/PSAN registration holders: roughly 3 to 5 months end-to-end
• Basic PSAN registrants: roughly 4 to 6 months

Do the arithmetic against a 1 July 2026 deadline. A provider beginning the process in, say, early 2026 with a 4–6 month timeline is cutting it close; one not yet started is at material risk of being unable to obtain authorization in time. The practical message for any provider reading this in mid-2026: if you are not already in the AMF process, engage French regulatory counsel immediately and treat the timeline as the binding constraint.

The upside: passporting

The migration is not only a compliance burden. The CASP authorization is passportable across the EU/EEA — something the national PSAN never offered. A provider that obtains French CASP authorization can, subject to the MiCA notification process, provide services into other Member States without separate national registrations. For a provider with EU expansion ambitions, the CASP authorization is the key to the single market. The migration is forced, but the destination regime is strictly broader than the one it replaces.

How this connects to DAC8

MiCA CASP authorization and DAC8 tax reporting are separate workstreams (see DAC8 vs MiCA). A provider completing the PSAN-to-CASP migration still has to build the DAC8 reporting pipeline independently — obtaining the licence does not satisfy the tax-transparency obligation. The two should be project-managed in parallel, because both have 2026 timelines.

Where Wag3s fits

The CASP authorization file itself, and the legal strategy behind it, are work for French regulatory counsel — Wag3s does not prepare or submit it. Where Wag3s Ledger helps is the financial-recordkeeping layer that both the authorization and the parallel DAC8 obligation rely on:

• Audit-ready transaction records of the kind the systems-and-controls expectations of a CASP application draw on.
• Multi-chain reconciliation feeding clean data into the DAC8 pipeline you have to build alongside the licence (see multi-chain reconciliation).
• Per-user aggregation aligned with DAC8 reportable fields.

Treat this as support for a counsel-led migration, not a substitute for it. See the Wag3s Ledger product page for module details.

Further reading

• MiCA Regulation: What It Means for Crypto Businesses
• MiCA Implementation Checklist
• MiCA ART vs EMT Stablecoins
• DAC8 vs MiCA
• DAC8 Compliance Guide 2026
• France Crypto Tax Guide 2026
• AML & KYC for Crypto Businesses

Practical checklist for PSAN providers approaching the deadline

This checklist is for PSAN holders assessing their migration position in mid-2026. It is not legal advice; each item needs confirmation with French regulatory counsel.

Step 1 — Confirm current registration type. Determine whether you hold a basic PSAN registration or an enhanced DASP/PSAN registration. The AMF fast-track timelines differ: enhanced holders have a shorter indicative process (roughly 3–5 months); basic registrants should budget roughly 4–6 months. If neither designation applies — if you were operating under an exemption or a grandfathering argument — treat yourself as outside the transitional period entirely and seek counsel immediately.

Step 2 — Audit the services you currently provide. MiCA's list of authorised CASP services is not identical to the PSAN activity list. Map each service you currently provide under PSAN to its MiCA equivalent. Some activities may require additional authorisation tiers; others may be covered by the core authorisation. This mapping drives the authorisation scope you apply for.

Step 3 — Assess your application readiness. MiCA CASP authorisation requires evidence of: governance and management structure; own funds (amount depends on the services applied for — ESMA has published the own-funds requirements by service tier); AML/KYC programme aligned with MiCA's CASP AML obligations; safekeeping and custody arrangements (if applicable); and complaint and conflicts-of-interest policies. Gaps here extend the AMF review.

Step 4 — File before the timeline window closes. Given the indicative AMF timelines, any provider not yet in the process by the time this article is published is at real risk of not obtaining a decision before 1 July 2026. Even if the application is submitted in time, a refusal terminates the right to operate at that point — not on 1 July. The only safe path is to have an active, complete application well before the deadline and to cooperate actively with any AMF requests for information.

Step 5 — Run the DAC8 workstream in parallel. The CASP authorisation concerns the right to operate; DAC8 concerns the obligation to report client activity to tax authorities from 1 January 2026. Both have 2026 deadlines; neither satisfies the other. A provider that obtains CASP authorisation without a functioning DAC8 reporting pipeline is authorised but non-compliant on tax transparency.

Sources

• AMF — reminder that the transitional period for DASPs ends 1 July 2026: states the 1 July 2026 hard stop and the criminal exposure under Articles L. 54-10-4 and L. 572-23.
• AMF — MiCA: AMF now accepting CASP authorisation applications: confirms applications accepted since 1 July 2024 and the indicative review periods.
• AMF — doctrine clarifying treatment of PACTE-Law DASPs and the MiCA transition: the AMF's published policy easing the PSAN-to-CASP move.
• Regulation (EU) 2023/1114 (MiCA) — EUR-Lex official text: the CASP regime (Title V) and its transitional provisions.
• AMF — the European MiCA regulation overview: France's competent-authority summary.