PSAN to CASP: The France MiCA Migration

France built its national crypto regime — the PSAN — under the 2019 PACTE law, years before MiCA. MiCA now replaces it with the EU-wide CASP authorization. The transition is not open-ended: the French transitional period ends 1 July 2026, with criminal exposure for providers that operate past it without a granted CASP authorization. This article lays out the timeline, the AMF process, and what affected providers must do now.

TL;DR

• 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.
• Early 2025 — AMF begins accepting MiCA CASP authorization applications.
• 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.

How Wag3s helps

Wag3s Ledger supports the financial-recordkeeping side that both the CASP authorization and DAC8 depend on:

• Audit-ready transaction records that support the systems-and-controls expectations of CASP authorization
• Multi-chain reconciliation feeding clean data into the parallel DAC8 pipeline (see multi-chain reconciliation)
• Per-user aggregation aligned with DAC8 reportable fields

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

Sources

• AMF — reminder that the MiCA transitional period for DASPs ends 1 July 2026
• AMF — MiCA: AMF accepting CASP authorisation applications
• Regulation (EU) 2023/1114 (MiCA) — EUR-Lex
• AMF — the European MiCA regulation overview