AMF/PSAN → Mica (PSCA/CASP) Authorisation Assistance: Practical Registration, Application and Transition Support for Firms Operating in France

Introduction Quick Summary and Conversion Offer

For any firm navigating PSAN MiCA France compliance, the transition from France’s national digital-asset registration regime to the European Union’s Markets in Crypto-Assets framework represents the single most consequential regulatory event since the PACTE law first created the PSAN category. This landing page provides a practitioner-level roadmap covering application documents, governance requirements, capital thresholds, AML/KYC controls, ICT resilience, custody rules and realistic timelines to help compliance officers, founders and in-house counsel convert an existing PSAN registration into a full MiCA PSCA/CASP authorisation before the hard deadline.

That deadline is 1 July 2026. The AMF has publicly reminded all digital-asset service providers that the transitional period allowing them to continue providing services under PSAN registration ends on that date. After 1 July 2026, only firms holding a MiCA PSCA/CASP authorisation or an equivalent licence where payment-service or stablecoin elements are involved may lawfully serve clients in France. The legal basis for this cut-off is Regulation (EU) 2023/1114 (MiCA), Article 143(3). The pages that follow break down exactly what firms must file, with whom, and on what timeline.

What Changed PSAN vs PSCA/CASP and the 1 July 2026 Deadline

Legal Basis: MiCA, Article 143 Transitional Clause and French Adaptation

Regulation (EU) 2023/1114, commonly known as MiCA, was published in the Official Journal of the European Union on 9 June 2023 and entered into force on 29 June 2023. Titles III and IV (covering asset-referenced tokens and e-money tokens) applied from 30 June 2024, while Title V which governs crypto-asset service providers (CASPs) applied from 30 December 2024. Article 143(3) of MiCA permits Member States to allow existing nationally registered service providers to continue operating under their domestic regime for a transitional period of up to 18 months from that Title V application date. France exercised this option to its maximum extent, setting the backstop at 1 July 2026.

Practical Difference: PSAN (PACTE National Registration) vs PSCA/CASP (MiCA Authorisation)

Under the French PACTE law (2019), the AMF administered PSAN registration a national-level process covering a defined set of digital-asset services such as custody, exchange, and platform operation. Registration was mandatory for certain services and optional (as an enhanced “agrément”) for others. The regime was confined to France; it conferred no EU passporting rights, and its prudential, governance and ICT requirements, while meaningful, were lighter than what MiCA now demands.

The PSCA/CASP authorisation under MiCA is a fundamentally different instrument. It covers ten enumerated crypto-asset services, requires full governance and fit-and-proper assessments, imposes detailed prudential capital requirements, mandates ICT risk management aligned with the Digital Operational Resilience Act (DORA), and critically allows the authorised firm to passport its services across the entire EU/EEA. The ACPR plays an active supervisory role where services involve e-money tokens (EMTs) or asset-referenced tokens (ARTs), or where payment-service elements require a dual authorisation.

What the Transitional Regime Means for PSANs in France

Firms that were already registered as PSANs and actively providing services before 30 December 2024 may continue to operate under their existing registration until 30 June 2026. On 1 July 2026, the transitional regime expires. Any PSAN that has not by then obtained a full MiCA PSCA/CASP authorisation must cease providing crypto-asset services in France. The ESMA list of Member State grandfathering periods confirms France’s election of the maximum 18-month window. There is no indication that a further extension will be granted.

Who Must Apply Eligibility and Scope

Existing PSAN Registrants

Every firm currently on the AMF’s PSAN register whether holding a simple registration (mandatory for custody and fiat-to-crypto exchange) or an enhanced agrément must apply for PSCA/CASP authorisation if it wishes to continue operating after 30 June 2026. This includes custodians, exchange platforms, over-the-counter dealers, and advisory firms. New entrants that were not registered as PSANs before 30 December 2024 cannot benefit from the transitional regime and must apply directly for MiCA authorisation. The current register of authorised PSANs is available on the AMF white list published via data.gouv.

Non-EU/Third-Country Firms and Cross-Border Provision

The transitional regime is strictly national. A PSAN registration does not authorise cross-border provision of services into other EU Member States, and third-country firms seeking to serve French clients must either establish a legal entity in France and obtain PSCA/CASP authorisation, or rely on the reverse-solicitation exemption (which MiCA construes narrowly). ESMA’s guidance on transitional measures underscores that grandfathering applies only within the notifying Member State.

Special Categories: EMT/ART Stablecoin-Related Services

Where a firm’s services involve the issuance or offering of e-money tokens or asset-referenced tokens, the ACPR has articulated specific expectations, including the potential requirement for a payment-institution or electronic-money-institution licence alongside PSCA authorisation. Firms in this category face dual-authorisation obligations and should engage with both AMF and ACPR early in the process to map the correct application pathway.

Step-by-Step Application Checklist: Documents, Governance, Capital, AML/KYC, IT/Cybersecurity and Custody Rules

The following checklist mirrors the regulatory expectations of the AMF and ACPR for a PSAN MiCA France transition application. It is organised into seven thematic blocks. Each numbered step corresponds to a deliverable that should be regulator-ready before submission.

A. Core Application Pack (AMF/PSCA)

1. Pre-application gap analysis and scoping. Map every crypto-asset service the firm currently provides (or plans to provide) against MiCA’s ten enumerated services. Identify target markets, customer segments and EU coverage. Determine whether ACPR co-supervision applies (EMT/ART issuance, payment services). This scoping exercise drives every subsequent deliverable.
2. Corporate documents. Prepare the full legal-entity dossier: articles of association, ownership chart up to the ultimate beneficial owner, declarations of beneficial ownership, KYC documentation on all shareholders holding a qualifying stake, and audited financial statements for the last two financial years (or pro forma projections for newer entities). The AMF’s filing expectations for PSAN-level applications provide a useful template, now supplemented by MiCA-specific requirements.
3. Programme of operations / business plan. Draft a comprehensive document covering services to be offered, target markets and client profiles, revenue model and projections, marketing plan and distribution channels, outsourced functions and their service-level agreements, and detailed onboarding flows (including customer acceptance and rejection criteria).

B. Governance and Fit-and-Proper

4. Governance pack. Set out the board composition, committee structure (audit, risk, compliance), and organisational chart. Prepare fit-and-proper dossiers for all senior managers and members of the management body, including CVs, criminal-record extracts, declarations of good repute, and evidence of relevant knowledge and experience. Designate the AML officer (MLRO/RCCI) with a formal mandate and provide their CV and training evidence.
5. Risk management and internal controls. Produce a compliance manual covering conflicts-of-interest identification and management, a complaints-handling policy aligned with MiCA Article 71, record-retention rules (minimum five years), and the internal-control function’s reporting lines and escalation procedures.

C. AML/KYC and Compliance Programme

6. AML/KYC framework. Deliver detailed know-your-customer procedures (onboarding, ongoing due diligence, periodic review), enhanced due diligence (EDD) protocols for high-risk clients and jurisdictions, transaction-monitoring rules with calibrated alert scenarios, sanctions-screening procedures, and the suspicious-activity report (SAR) filing process with Tracfin. Include evidence of AML automation tooling, sample alert scenarios, case-management screenshots and volume thresholds.

D. Financial Resources and Capital

7. Capital and prudential evidence. Provide proof of initial capital (MiCA sets minimum own-funds requirements depending on the services provided ranging from €50,000 to €150,000, with higher thresholds for trading-platform operators), liquid-resource schedules, and solvency tests. Where the ACPR supervises prudential elements (EMT/ART issuance, payment overlap), additional capital-adequacy evidence may be required. Include bank statements, auditor confirmations and ongoing monitoring arrangements.

E. ICT/Cybersecurity and DORA Alignment

8. IT and cybersecurity dossier. Present the ICT risk-management framework, incident-detection and response procedures, penetration-testing schedule and most recent test results, data-encryption standards, access-control policies, and supplier/third-party risk assessments. Alignment with DORA (Regulation (EU) 2022/2554) is strongly recommended and, for many firms, will become directly applicable. Document business-continuity and disaster-recovery plans with tested recovery-time objectives.

F. Custody and Client-Asset Segregation

9. Custody and segregation arrangements. Detail the key-management architecture (cold storage, warm wallets, multi-signature protocols), insurance coverage or equivalent guarantees, proof of client-asset segregation (on-chain and off-chain), and the reconciliation frequency. Where the firm uses third-party custodians, provide the outsourcing agreement, SLAs and evidence of due diligence on the sub-custodian.

G. Operational Readiness and Submission Annexes

10. Operational readiness evidence. Customer-support arrangements (response-time commitments, staffing levels), dispute-handling and mediation framework, continuity and recovery plans, and testing evidence from onboarding-environment simulations.
11. AML automation and transaction-monitoring evidence. Provide documented sample alert scenarios, case-management workflow screenshots, volume thresholds, and tuning records for the monitoring system.
12. Draft regulatory communications. Website risk disclosures, marketing-compliance statements per MiCA Article 66, product terms and conditions, and (for token issuers or trading-platform operators) crypto-asset white papers and admission-to-trading documentation.
13. Submission annexes. Model policies, sample client contracts, outsourcing agreements, SLAs, and any templates required by the AMF’s submission portal. Consolidate the dossier with a clear index and cross-references to MiCA articles.

Comparison Table PSAN (PACTE) vs PSCA/CASP (MiCA)

The table below summarises the principal differences between the outgoing French PSAN regime and the incoming PSCA/CASP authorisation under MiCA. Understanding these distinctions is essential for any firm planning its PSAN MiCA France transition strategy.

Timelines, Fees and Common Rejection Reasons

Typical Regulator Timelines

The AMF opened PSCA authorisation applications in line with MiCA Title V’s application date of 30 December 2024. Industry observers report that realistic processing windows for a complete and well-prepared dossier range from three to six months, though applications involving parallel ACPR review (EMT/ART prudential elements) or complex multi-jurisdictional structures can take longer. The AMF may issue formal questions or requests for supplementary information that stop the assessment clock, effectively extending the timeline. Given the 1 July 2026 hard deadline, firms that have not yet submitted should treat their applications as critically urgent.

Fees and Cost Drivers

AMF application fees for PSCA authorisation are published on the AMF website and are broadly comparable to the fees for enhanced PSAN agrément, adjusted for the expanded scope of review. Beyond regulator fees, firms should budget for:

• External audit and legal advisory: preparation and review of the programme of operations, governance packs, and AML frameworks.
• Capital buffers: meeting minimum own-funds requirements and maintaining ongoing prudential ratios.
• Operational uplift: ICT/cybersecurity enhancements, DORA-aligned incident-response capabilities, AML transaction-monitoring tooling, and staff training.
• Ongoing compliance costs: regulatory reporting, periodic audits, and annual supervisory contributions.

Illustrative cost bands vary significantly by firm size and service complexity. Industry commentary suggests total one-off transition costs (excluding capital) of €100,000–€500,000 for mid-market operators, though bespoke estimates are essential.

Common Rejection Reasons and Remediation Tips

Based on regulator communications and practitioner experience, the most frequent grounds for application delay or refusal include:

• Inadequate fit-and-proper evidence: missing criminal-record extracts, undeclared conflicts, or insufficient demonstration of relevant experience for senior managers.
• Weak AML/KYC controls: generic compliance manuals without tailored risk assessments, absence of transaction-monitoring evidence, or poorly documented sanctions-screening processes.
• ICT/cybersecurity gaps: no penetration-testing evidence, undocumented incident-response procedures, or failure to address DORA requirements.
• Unclear custody and security model: inadequate description of key-management architecture, no proof of client-asset segregation, or absence of insurance/guarantee arrangements.
• Incomplete capital evidence: failure to demonstrate minimum own-funds, missing auditor confirmations, or unrealistic financial projections.
• Poorly documented outsourcing: SLAs without measurable service levels, unidentified sub-contractors, or missing due-diligence records on critical third-party providers.

Remediation should begin with a targeted gap analysis against each MiCA requirement, followed by prioritised remediation sprints focused on the weakest areas first.

Enforcement Risks and AMF Withdrawal Notices

Enforcement Landscape

The AMF has intensified its supervisory posture as the transition deadline approaches. Public reminders, withdrawal notices and updates to the AMF blacklist signal a zero-tolerance approach to firms attempting to operate without valid authorisation after 1 July 2026. Under French law, providing digital-asset services without the required authorisation constitutes an offence that can trigger administrative sanctions (fines, injunctions, publication of sanctions decisions) and, in serious cases, criminal prosecution for unauthorised financial-services activity. The EBA has also advised national authorities on actions to take at the end of the transition period, reinforcing the expectation of firm enforcement across Member States.

How AMF/ACPR Coordinate Enforcement

The AMF retains primary supervisory and sanctioning authority over PSCA-authorised firms. The ACPR exercises concurrent jurisdiction over prudential matters relating to EMT and ART issuers and firms providing payment services. Cross-border enforcement coordination is facilitated through ESMA (for market-conduct matters) and the EBA (for prudential and AML supervision). Referral mechanisms ensure that a deficiency identified by one authority is communicated to the other, and both regulators may impose parallel supervisory measures where necessary.

Remediation and Withdrawal Response

When the AMF issues a deficiency letter or provisional withdrawal of a PSAN registration, best practice requires immediate containment: the firm should halt onboarding of new clients, issue cessation-of-offering notices to existing clients, and engage with the regulator to clarify the scope of the deficiency. A consumer-remediation plan covering client-asset return, complaint resolution and orderly wind-down where necessary should be prepared and submitted promptly. Firms that respond proactively and transparently are more likely to negotiate a manageable resolution timeline.

Supporting Resources

The following regulator and institutional sources underpin the guidance on this page. Firms preparing PSAN MiCA France transition applications should consult these primary materials directly:

• AMF PSAN registration guidance and filing portal: amf-france.org
• AMF Press release on transitional period ending 1 July 2026: amf-france.org
• EUR-Lex Regulation (EU) 2023/1114 (MiCA): eur-lex.europa.eu
• ACPR Crypto-asset issuers and service providers guidance: acpr.banque-france.fr
• data.gouv AMF white list of registered PSANs: data.gouv.fr
• ESMA List of MiCA grandfathering periods (Article 143(3)): esma.europa.eu
• EBA Opinion on end of transition period (12 February 2026): eba.europa.eu