A legal basis for cross-border reporting
The Senate passed Bill No. 921 at first reading and sent it to the National Assembly, where it is numbered Bill No. 3421. The Assembly must approve it before it can become law.
The legislation would ratify two agreements France signed in Asunción, Paraguay, on November 26, 2024: the OECD Multilateral Competent Authority Agreement for automatic information exchange under the Crypto-Asset Reporting Framework, known as MCAA-CARF, and an addendum to the agreement governing the Common Reporting Standard.
The data-sharing bill does not itself impose a tax. Its purpose is to authorize exchanges of information already collected by tax authorities; the proposed change to stablecoin taxation is proceeding through the 2027 budget.
What providers would report
CARF would require reporting crypto-asset service providers to identify users by name, tax residence and tax identification number. For each asset and transaction type, providers would also report transaction counts, quantities and aggregate values.
The framework covers conversions between crypto and fiat currency, swaps between crypto assets, and transfers. Certain transfers involving self-custody wallets would also be reportable, but that reporting would not allow tax authorities to enter or directly access those wallets.
International CARF exchanges are scheduled to begin in 2027, initially with an expected 46 jurisdictions, including France, Germany, the United Kingdom, Japan and Canada. Altogether, 77 jurisdictions have committed to adopting the framework across 2027, 2028 and 2029.
France's domestic collection of crypto data under the EU's DAC8 rules began on January 1, 2026. The first exchanges under that regime, covering information collected during 2026, are due by September 30, 2027.
Which stablecoin swaps would become taxable
The National Assembly approved budget amendment I-3898 on October 16, 2026, in a 38-37 vote, with 25 abstentions. It would end tax deferral for crypto-to-crypto swaps when investors receive an e-money token covered by the EU's Markets in Crypto-Assets framework, or MiCA.
If the measure becomes law, gains on those swaps would be subject to France's 31.4% flat rate on private crypto gains from January 1, 2027. The amendment still has to pass through the remaining budget stages and could be changed or removed.
Its scope would include MiCA-compliant stablecoins such as USDC and EURC, but not USDT. Although USDT is the world's largest stablecoin, it has not obtained MiCA authorization and would remain outside the proposed tax on crypto-to-stablecoin swaps.
Amendment I-3898 would also replace the portfolio-wide method of calculating taxable gains. A disposal's gain would instead depend on the acquisition cost of the assets sold, with a weighted-average cost used when units of the same cryptocurrency were purchased at different prices.
A separate proposal for taxpayers moving abroad
Another amendment, proposed by Nicolas Sansu, would bring crypto holdings within France's exit tax. It would tax unrealized gains when a taxpayer transfers their tax residence abroad.
The proposal would cover moves from January 1, 2027, where a tax household holds more than €800,000 in crypto, including assets kept with custodians. It would also require the taxpayer to have been a French tax resident for at least six of the preceding 10 years.
Centralized records raise security concerns
The European Commission plans to establish a central repository for crypto tax reports by the end of 2026. Tax authorities in each member state would be able to retrieve information concerning that country's tax residents.
Faustine Fleuret, representing Morpho's global public affairs, has warned that centralizing these records carries substantial personal-data security risks. Those concerns come amid reports of "wrench attacks," in which attackers use physical intimidation to seize cryptocurrency.
Blockchain security company CertiK recorded 52 verified wrench attacks worldwide in the first half of 2026, with 33 occurring in France.
