MiCA regulation in France: Licensing, implementation, and what crypto firms need to know

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General Counsel

Aug 05, 2025

6 min. read

MiCA regulation in France: Licensing, implementation, and what crypto firms need to know

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MiCA regulation in France: Licensing, implementation, and what crypto firms need to know

In this article

France is setting a new standard for crypto compliance, and the Markets in Crypto-Assets Regulation (MiCA) is at the heart of it. This article walks you through how MiCA became French law, the dual-authority framework you’ll navigate, the licence requirements every service provider faces, and the critical dates you can’t afford to miss. 

You’ll also get practical advice on engaging regulators, building your authorisation dossier, and staying ahead of evolving technical standards. Whether you’re a PSAN veteran or a newcomer eyeing the French market, you’ll finish this read with a clear action plan to turn MiCA from a hurdle into a competitive edge.

How MiCA transforms crypto compliance in France

I’ve watched the Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114) go from concept to reality—and it’s a game-changer for crypto in Europe. From 30 June 2024, asset-referenced tokens (ARTs) and e-money tokens (EMTs) fall under EU rules. 

By 30 December 2024, every Crypto-Asset Service Provider (CASP) must hold full authorisation. To keep pace, France rolled out Ordinance 2024-936 on 15 October 2024 and Decree 2025-169 on 21 February 2025, weaving MiCA into the Monetary and Financial Code and spelling out licence hoops and prudential requirements. Let’s break down what this means for your business in France.

France’s dual-authority model keeps you honest and transparent

France didn’t leave crypto oversight to chance. The Autorité des Marchés Financiers (AMF) handles CASP licences—trading, custody, brokerage and exchange. Meanwhile, the Autorité de Contrôle Prudentiel et de Résolution (ACPR), alongside the Banque de France, keeps an eye on ART and EMT issuers to safeguard financial stability. 

Better yet, the AMF publishes two registers: one for authorised CASPs and another warning list for unauthorised providers. Don’t guess who’s compliant—look it up.

Every crypto service in France needs a licence—no exceptions

MiCA Article 2(1) is unambiguous: if you “professionally provide” crypto services, you need a CASP licence. That covers everything from centralised exchanges and custodial wallets to portfolio advice and crypto-fiat conversions. 

If you were already a PSAN under France’s 2019 Loi PACTE, you get an 18-month runway—apply by 30 June 2026 or shut down. From 30 December 2024, any newcomer must hold a MiCA licence to operate here.

Your application dossier must include:

  • Program of Activities outlining every service, market and jurisdiction.
  • Governance & Fit-and-Proper: roles, org chart, and attestations proving your leadership’s integrity.
  • Risk Management & AML/CFT plans that align with MiCA’s Travel-Rule and France’s AML law.
  • Technical Resilience: ICT diagrams, pentest reports and disaster-recovery plans.
  • Prudential Resources: own funds (€50 000–€150 000), segregation schemes and cold-wallet insurance.
  • White Paper & Disclosure (for ART/EMT): clear details on token rights, fees and redemption.

France’s MiCA roll-out: Key dates you can’t miss

France kept its foot on the gas to transpose MiCA. Here’s your quick reference:

DateMilestone
20 April 2023MiCA adopted by the European Parliament.
30 June 2024ART/EMT rules enter into force across the EU.
1 July 2024AMF opens the door for CASP licence applications.
15 October 2024France enacts Ordinance 2024-936 to adapt its national code.
21 February 2025Decree 2025-169 details prudential requirements and licence steps.
30 December 2024Full MiCA CASP regime kicks in; no licence, no operation.
30 June 2026Last call for pre-existing PSANs to secure MiCA authorisation.
MiCA implementation timeline in France

Nail your MiCA strategy by engaging regulators early

I recommend booking pre-application meetings with both the AMF and ACPR. Get clarity on dossier formats, fees and review timelines. Remember, AMF handles CASPs; ACPR oversees ART/EMT prudential rules. Sync your filings to avoid duplicate requests. 

Meanwhile, upgrade your transaction-monitoring tools for MiCA’s Travel-Rule, and brace for on-site AML inspections by Tracfin and ACPR. Finally, strengthen your governance by updating conflicts-of-interest policies and documenting key decisions.

Your blueprint to MiCA readiness

Here’s how I’d tackle MiCA authorisation step by step:

  1. Conduct a Gap Analysis: Map your policies, systems and controls against MiCA, Ordinance 2024-936 and Decree 2025-169.
  2. Build the Dossier: Program of activities, governance guides, ICT schematics, AML/CFT manual, financials and white papers.
  3. Consult the Regulators: Refine your submission, confirm fee estimates and negotiate realistic timelines.
  4. Train Your Team: Educate everyone on reporting cycles, breach-notifications and EU passporting.
  5. Monitor Updates: Keep an eye on ESMA’s technical standards and AMF/ACPR circulars—today’s Q&A can reshape tomorrow’s rulebook.

Streamline MiCA compliance with CyberUpgrade

Meeting MiCA’s rigorous requirements—from whitepaper filings to ongoing governance and transparency—often means endless manual tracking and audit prep. CyberUpgrade automates your MiCA workflows with prebuilt templates and real-time Slack or Teams prompts, keeping policies, risk assessments, and evidence audit-ready in one central hub.

Beyond MiCA, CyberUpgrade also supports DORA, ISO 27001, and NIS 2 frameworks, letting you “map once, prove many” across multiple regulations. Automated data extraction, vulnerability scans, and KPI dashboards feed each regulator’s portal seamlessly, reducing manual work by up to 80 %.

With fractional CISO services guiding your continuous monitoring and customizable compliance workflows, you’ll secure faster approvals, avoid fines, and adapt as MiCA and related frameworks evolve—turning compliance from a hurdle into a strategic advantage.

Are you ready for Europe’s unified crypto market?

By embracing MiCA’s rigorous licensing, governance and prudential rules—and partnering closely with the AMF and ACPR—you’ll not only secure legal certainty but also position your firm for rapid expansion across the EU. If you’re curious about tailoring this roadmap to your platform or have questions on any step, reach out to CyberUpgrade. Let’s make compliance your competitive edge in 2025 and beyond.

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General Counsel

He is regulatory compliance strategist with over a decade of experience guiding fintech and financial services firms through complex EU legislation. He specializes in operational resilience, cybersecurity frameworks, and third-party risk management. Nojus writes about emerging compliance trends and helps companies turn regulatory challenges into strategic advantages.
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