France AMF tokenization regulation framework and PACTE law compliance for digital assets

France AMF Tokenization Regulation & PACTE Law Guide

ByTokenizeStartup Editorial

When comparing tokenization regulations by country, France established itself as a premier European jurisdiction for digital assets long before the European Union harmonized its rules. The introduction of the PACTE law in 2019 provided a clear regulatory structure that attracted both startup token issuers and major legacy financial institutions to the French market. Today, the France AMF tokenization regulation framework serves as a bridge between national initiatives and the broader European capital markets. For those learning what is asset tokenization, understanding how the Autorité des Marchés Financiers (AMF) handles digital assets reveals the practical realities of launching compliant tokenized products in a major Group of Seven economy.

This guide examines the mechanics of French digital asset regulation, the transition toward unified European rules, and the institutional projects that have tested these legal boundaries in production environments. We detail the specific compliance costs, the registration timelines, and the regulatory classifications that determine how tokens are treated under French law. France offers a mature ecosystem with a regulator that understands blockchain technology, but operating within this jurisdiction requires navigating complex bureaucratic processes and strict anti-money laundering requirements.

The PACTE law and digital asset definitions

The PACTE law, enacted on May 22, 2019, established France’s foundational legal framework for digital assets. Through Article L54-10-2 of the French Monetary and Financial Code, the legislation created specific definitions for tokens and formalized the regulatory perimeter for service providers operating within the French jurisdiction.

The Plan d’Action pour la Croissance et la Transformation des Entreprises, universally referred to as the PACTE law, fundamentally altered how the French state interacted with blockchain technology. Before its passage, digital assets existed in a legal gray area that discouraged institutional participation and complicated tax treatment for retail investors. By modifying the French Monetary and Financial Code (Code monétaire et financier), lawmakers provided a statutory definition for digital assets that separated them from traditional financial instruments. The law defines a digital asset as any digital representation of value that is not issued or guaranteed by a central bank or a public authority, which can be transferred, stored, or traded electronically.

This definition intentionally captures cryptocurrencies and utility tokens while excluding securities, which remain governed by existing financial market regulations. The clarity provided by PACTE allowed France to attract blockchain enterprises looking for legal certainty rather than regulatory arbitrage. By establishing this framework early, the French government positioned Paris as a viable alternative to other European financial centers navigating the fallout of Brexit. The law demonstrated a willingness to accommodate new technological paradigms without forcing them into ill-fitting legacy legal categories. It also created a clear boundary line for regulators to enforce consumer protection standards on companies interacting with the French public.

French DASP registration and the AMF framework

The AMF digital asset regulation framework requires mandatory registration for companies providing digital asset custody or fiat-to-crypto exchange services. This Prestataires de Services sur Actifs Numériques (PSAN) regime enforces strict anti-money laundering controls, management fitness standards, and operational requirements for firms targeting the French market.

The Autorité des Marchés Financiers administers the French DASP registration system, which operates on a dual-tier model of mandatory registration and optional licensing. Any entity wishing to provide digital asset custody services to third parties, or operate a service buying and selling digital assets for legal tender, must register with the AMF before commencing operations in France. The registration process requires applicants to demonstrate robust anti-money laundering and counter-terrorist financing (AML/CFT) procedures, which are vetted in coordination with the Autorité de Contrôle Prudentiel et de Résolution (ACPR). Applicants must also prove the good repute and competence of their senior management and beneficial owners. The AMF maintained a public registry of these approved entities, which grew to include over 100 registered service providers by early 2024, according to official AMF registry data.

Beyond the mandatory registration floor, the AMF framework introduced an optional licensing tier for a broader array of digital asset services, including crypto-to-crypto exchange, trading platform operation, and digital asset portfolio management. This optional license demands significantly higher operational standards, including professional indemnity insurance, minimum capital requirements, and resilient IT infrastructure. Very few firms pursued the optional license due to its stringent requirements, preferring to operate solely under the mandatory registration tier. The PSAN regime effectively cleaned up the French retail crypto market by forcing non-compliant offshore exchanges to either register locally or cease targeting French consumers. This approach provided a template for subsequent European legislation, proving that national regulators could enforce compliance on decentralized technologies without stifling domestic industry growth.

The optional ICO visa process

The AMF optional ICO visa allows token issuers to obtain regulatory approval for utility token offerings in France. Applicants must submit a comprehensive white paper, implement escrow mechanisms for raised funds, and establish rigorous investor identification procedures to receive this official regulatory endorsement.

One of the most distinct features of the PACTE law was the creation of the visa optionnel AMF pour les offres de jetons, an optional approval mechanism for Initial Coin Offerings. Unlike jurisdictions that banned token sales or forced them into strict securities frameworks, France offered a voluntary compliance path for utility tokens. Issuers could apply for an AMF visa by submitting a detailed white paper that clearly outlined the project’s technical specifications, the token’s economic model, and the associated risks. The regulator reviewed these documents to ensure the information was accurate, clear, and not misleading to potential buyers. The process required the issuer to be incorporated in France and to implement a system for monitoring and safeguarding the funds raised during the token sale.

The practical value of the ICO visa generated considerable debate within the French legal community following its introduction. While the visa provided a powerful marketing tool and facilitated access to corporate banking services, the regulatory burden deterred many potential applicants. According to AMF publications, only a handful of projects successfully obtained the visa in the years following the PACTE law’s enactment. Most issuers chose to conduct unregistered sales, which remained perfectly legal provided they did not actively market to the French public or cross the threshold into offering financial securities. The low uptake of the optional visa highlighted the tension between regulatory certainty and speed to market in the digital asset sector. However, the rigorous standards developed for the visa process heavily influenced how French regulators approach the disclosure requirements for digital assets today.

Security token offerings under French financial law

A France security token offering must comply with traditional financial regulations, as tokens representing equity or debt are classified as financial instruments. These offerings fall under the EU Prospectus Regulation and MiFID II requirements, completely bypassing the PACTE digital asset framework.

When a tokenized asset exhibits the characteristics of a traditional security, such as conferring voting rights, dividend entitlements, or debt obligations, it falls entirely outside the PACTE law’s definition of a digital asset. Instead, these instruments are governed by the French transposition of the Markets in Financial Instruments Directive (MiFID II) and the AMF General Regulation. Firms evaluating the best country to launch an STO often look to France because issuing a security token requires the same rigorous legal structuring as issuing traditional shares or bonds. If the offering is made to the public and exceeds the €8 million threshold over a 12-month period, the issuer must publish a prospectus approved by the AMF, in accordance with the European Union Prospectus Regulation. Offerings below this threshold, or those restricted entirely to qualified institutional investors, can utilize standard exemptions to avoid the costly prospectus requirement.

The intersection of blockchain technology and traditional securities law requires careful navigation of settlement and custody rules. French law permits the registration of unlisted financial securities on a shared electronic recording device (dispositif d’enregistrement électronique partagé, or DEEP), effectively legalizing blockchain-based capitalization tables. This approach contrasts with the Germany eWpG tokenization rules and the Switzerland DLT Act framework, which created entirely new legal categories for digital securities. However, secondary market trading of these instruments in France remains constrained by European rules requiring multilateral trading facilities to settle transactions through central securities depositories. To address this friction, the EU introduced the DLT Pilot Regime, which allows authorized market infrastructure operators in France and other member states to test trading and settlement of security tokens on a single platform. This regulatory sandbox approach enables the French market to experiment with full lifecycle tokenization while maintaining the investor protection standards mandated by MiFID II.

Societe Generale FORGE and institutional tokenization

Societe Generale FORGE represents France’s most significant institutional tokenization initiative. The bank’s digital asset subsidiary has executed landmark transactions on public blockchains, including a €100 million covered bond on Ethereum and the issuance of the EURCV stablecoin, demonstrating viable enterprise use cases.

The French institutional tokenization landscape is heavily anchored by Societe Generale FORGE (SG-FORGE), a fully integrated subsidiary of the major French investment bank. SG-FORGE has systematically tested the legal and technical boundaries of issuing traditional financial instruments on distributed ledger technology. In April 2019, the group executed one of the first major institutional transactions on a public blockchain by issuing a €100 million covered bond as a security token directly on the Ethereum mainnet. This transaction proved that public blockchains could support the complex legal structuring required for institutional-grade debt instruments under French law. The firm followed this with a €40 million issuance settled in central bank digital currency in 2020, working in direct coordination with the French central bank.

The scope of SG-FORGE’s operations expanded significantly in 2021 when it issued a €5 million structured product in the format of a French government bond (OAT) on the public Tezos blockchain. This issuance diversified the underlying ledger technology and demonstrated cross-chain competency within a heavily regulated banking environment. More recently, SG-FORGE obtained its DASP registration and launched EUR CoinVertible (EURCV), a euro-denominated stablecoin deployed on Ethereum. According to the platform’s technical documentation, EURCV is designed to bridge traditional capital markets and the decentralized finance ecosystem, providing a compliant settlement asset for institutional on-chain transactions. The progression from experimental bond issuances to operating a regulated stablecoin illustrates a deliberate strategy to build comprehensive digital asset infrastructure within the confines of French and European financial regulation.

Other institutional initiatives and wholesale CBDC

The French tokenization ecosystem includes major projects from BNP Paribas and Credit Agricole CIB, supported by the Banque de France’s extensive wholesale central bank digital currency experiments. These efforts are coordinated through industry groups like Paris EUROPLACE to establish France as a European blockchain hub.

Beyond Societe Generale, the broader French banking sector has aggressively pursued distributed ledger technology to modernize capital markets infrastructure. BNP Paribas has integrated tokenization into its global markets division, utilizing digital assets to streamline the issuance and lifecycle management of structured products. Credit Agricole CIB has partnered with other financial institutions to test blockchain-based syndication and settlement processes, aiming to reduce the operational friction inherent in traditional loan markets. These private sector initiatives are heavily supported by the proactive stance of the Banque de France. The French central bank has been a global leader in wholesale central bank digital currency (wCBDC) experimentation, launching a comprehensive testing program in 2020 to evaluate how a tokenized euro could settle transactions involving tokenized financial assets.

The Banque de France’s experiments successfully demonstrated that a wCBDC could integrate with various proprietary and public blockchains to execute delivery-versus-payment settlement securely. These trials involved multiple international banks and proved the technical feasibility of cross-border, cross-currency settlements using distributed networks. Supporting this institutional momentum is Paris EUROPLACE, the organization representing the French financial services industry. Paris EUROPLACE has actively promoted the development of a robust digital asset ecosystem, advocating for favorable tax and regulatory policies to attract blockchain engineering talent and capital. Their efforts have helped cultivate a dense network of legal advisors, technology providers, and compliance specialists in Paris, creating a support infrastructure that lowers the barrier to entry for new tokenization projects.

Transitioning from PACTE to the MiCA framework

The French national digital asset regime is currently transitioning to the European Union’s Markets in Crypto-Assets regulation. Starting December 30, 2024, new service providers must obtain MiCA CASP authorization, while existing French DASPs operate under a transitional grandfathering period managed by the AMF.

The bespoke regulatory environment created by the PACTE law is now being superseded by the EU MiCA tokenization framework, which aims to harmonize digital asset rules across all member states. From December 30, 2024, companies seeking to provide digital asset services in France must apply for Crypto-Asset Service Provider (CASP) authorization under the MiCA framework rather than the legacy PSAN registration. The AMF continues to serve as the national competent authority responsible for administering these new European rules within France. For firms already registered as DASPs under the French system, a transitional period allows them to continue operations while they upgrade their compliance frameworks to meet the more rigorous MiCA standards. This transition requires significant operational adjustments, as MiCA imposes stricter capital reserves, enhanced governance protocols, and comprehensive consumer protection disclosures that exceed the baseline requirements of the original PACTE registration.

Launching a tokenization platform in France during this transitional phase involves substantial capital and operational commitments. Based on industry practice, legal structuring for a compliant token issuance or platform launch typically ranges from €75,000 to €200,000, depending on the complexity of the underlying assets. The regulatory application process itself incurs costs between €30,000 and €80,000, while ongoing annual compliance, audit, and reporting obligations generally require €40,000 to €120,000. Historically, securing AMF DASP registration took four to eight months, but the transition to MiCA CASP authorization is expected to require longer processing times as regulators adapt to the new European standards. Despite these costs, France offers distinct advantages, including a regulator intimately familiar with blockchain mechanics, a deep pool of institutional partners, and the ability to passport MiCA licenses across the entire European Economic Area. The primary disadvantages remain the strict French language requirements for formal regulatory interactions and a bureaucratic process that can move slower than in smaller, more agile jurisdictions.

France’s approach to digital assets demonstrates the value of early regulatory clarity. By establishing the PACTE law and the AMF registration framework in 2019, the country provided the legal foundation necessary for institutions like Societe Generale and BNP Paribas to build production-grade tokenization infrastructure. While the transition to the European MiCA framework introduces new compliance costs and operational demands, it also validates the core principles of the French model on a continental scale. Companies looking to launch tokenized assets or digital financial services must carefully evaluate the capital requirements and regulatory timelines associated with the AMF and MiCA regimes. For well-capitalized projects seeking access to the European market, France remains a premier jurisdiction backed by a regulator that understands the technical realities of distributed ledger technology. For specific definitions of the legal terms used in this guide, consult our tokenization glossary.

Frequently Asked Questions

What is the PACTE law in relation to tokenization?

Enacted in May 2019, the PACTE law created France’s legal framework for digital assets. It established the definition of digital tokens and introduced the regulatory regime for digital asset service providers operating within the country.

Does the AMF regulate security tokens in France?

Yes, the AMF regulates security tokens under traditional financial laws rather than the digital asset framework. Tokens representing equity or debt are classified as financial instruments and must comply with MiFID II and the EU Prospectus Regulation.

What is the AMF optional ICO visa?

The AMF optional ICO visa is a voluntary regulatory approval for utility token sales in France. Issuers must submit a detailed white paper, implement escrow procedures, and enforce strict anti-money laundering controls to receive this official endorsement.

How does MiCA affect French digital asset companies?

The European MiCA regulation replaces France’s national digital asset framework. Starting December 30, 2024, new companies must obtain MiCA authorization, while existing French registered providers operate under a transitional period to upgrade their compliance systems.

What is Societe Generale FORGE?

Societe Generale FORGE is the digital asset subsidiary of the French investment bank. The platform has issued major tokenized financial instruments, including a €100 million covered bond on Ethereum and the EURCV stablecoin, demonstrating institutional blockchain adoption.

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