Key points
- PSAN was the French status of digital asset service providers (prestataires de services sur actifs numériques).
- The European MiCA Regulation created the status of crypto-asset service provider (CASP, PSCA in French).
- Since 1 July 2026, the transitional period has ended and the articles of the French Monetary and Financial Code on PSANs have been repealed.
- Providing a crypto-asset service in the Union now requires MiCA authorisation, except for certain financial entities that are already authorised.
What is a PSAN in France?
PSAN stands for prestataire de services sur actifs numériques (digital asset service provider). It was the French status of businesses that held crypto-assets in custody for their clients, exchanged them for euros or operated a platform. It was based on mandatory registration with the AMF (French financial markets authority) for certain services, and on optional authorisation, both provided for by the French Monetary and Financial Code.
This status now belongs to the past. The vocabulary has changed too: the law refers to crypto-assets, defined by reference to the European MiCA Regulation (Article L. 54-10-1 of the French Monetary and Financial Code (Code monétaire et financier) (in French)).
What changed with the MiCA Regulation: from PSAN to CASP
Regulation (EU) 2023/1114 (MiCA) has applied to crypto-asset service providers since 30 December 2024. Its Article 143(3) allowed providers already operating in accordance with national law to continue until 1 July 2026, or until their authorisation was granted or refused if that happened earlier. In France, Ordinance No. 2024-936 of 15 October 2024 (in French) repealed, with effect from 1 July 2026, Articles L. 54-10-2, L. 54-10-3, L. 54-10-5 and L. 54-10-6 of the Monetary and Financial Code, which governed the registration and authorisation of PSANs (Articles 32 and 49 of the Ordinance).
The new status is that of crypto-asset service provider. Article 59 of the Regulation lays down the principle: no one may provide such services in the Union without being authorised as such, or without being a financial entity permitted to provide them (credit institution, investment firm, electronic money institution, management company, in particular). For the conditions of this authorisation, see our article on crypto-asset service providers and their obligations.
The services concerned
Article 3(1), point (16), of the MiCA Regulation lists the crypto-asset services:
- providing custody and administration of crypto-assets on behalf of clients;
- operation of a trading platform for crypto-assets;
- exchange of crypto-assets for funds;
- exchange of crypto-assets for other crypto-assets;
- execution of orders for crypto-assets on behalf of clients;
- placing of crypto-assets;
- reception and transmission of orders for crypto-assets on behalf of clients;
- providing advice on crypto-assets;
- providing portfolio management on crypto-assets;
- providing transfer services for crypto-assets on behalf of clients.
What this means for you
If you use a platform or a custody service, check that it holds MiCA authorisation, or that it is a permitted financial entity. Since 1 July 2026, the former PSAN registration is no longer sufficient. If you operate such a service yourself, operating without authorisation exposes you to sanctions and to having to cease the activity.
Our crypto-asset lawyer in Paris helps you classify your activity and prepare your authorisation application.
Every situation is different: the information on this page is general and does not replace legal advice tailored to your case. The firm makes no promise of outcome; it commits to the means it deploys.
