PSAN (Prestataire de Services sur Actifs Numériques)
PSAN (Prestataire de Services sur Actifs Numériques) is the French regulatory framework for digital asset service providers, established by the PACTE Law of 2019 under AMF oversight, and transitioning to the EU MiCA CASP framework.
PSAN — Prestataire de Services sur Actifs Numériques (Digital Asset Service Provider) — is the French regulatory category for entities providing services relating to digital assets. Established by the PACTE Law (Loi PACTE, May 2019) and codified in the French Monetary and Financial Code (Code monétaire et financier), the PSAN framework was one of the earliest comprehensive national digital asset regulatory frameworks in the European Union, predating MiCA by four years.
Regulatory Authority: AMF
The Autorité des marchés financiers (AMF) is the French securities regulator responsible for PSAN registration and authorisation. The AMF maintains a public register of registered and authorised PSANs, operates the PSAN application portal, and coordinates with the Autorité de contrôle prudentiel et de résolution (ACPR — the prudential banking supervisor) on AML/CFT compliance oversight.
Registration vs Authorisation: The Two-Track System
The PSAN framework originally offered two tracks:
Voluntary registration (enregistrement): Available from 2019. Registration required AML/CFT compliance and a fit-and-proper assessment of management but did not mandate capital requirements or conduct-of-business rules. Registration was open for a defined set of digital asset services.
Voluntary authorisation (agrément): A more rigorous approval process, requiring capital requirements, professional indemnity insurance, cybersecurity standards, client asset segregation, and compliance with detailed conduct rules — closer to a full financial licence.
Mandatory Registration: 2023 Evolution
Following the TerraUSD/LUNA collapse in May 2022, the Loi DDADUE (December 2022) and subsequent regulatory updates made PSAN registration mandatory for specified digital asset service categories, effective as of January 2023 for new entrants and with a transitional period for existing operators. Mandatory registration requirements applied to:
- Custody of digital assets
- Purchase or sale of digital assets for legal tender
- Exchange of digital assets for other digital assets
- Operation of a digital asset trading platform
The mandatory registration regime imposed enhanced AML/CFT requirements aligned with FATF standards, including full CDD, Travel Rule compliance, SAR reporting, and screening against EU sanctions lists.
What PSAN Covers
The PSAN framework applies to providers offering any of the following services on a professional basis:
- Custody of digital assets on behalf of third parties
- Buying or selling digital assets against legal tender (fiat exchange)
- Buying or selling digital assets against other digital assets
- Operation of a digital asset trading platform
- Receiving and transmitting orders for digital assets on behalf of third parties
- Portfolio management on digital assets
- Advice on digital assets
- Underwriting and/or placing of digital assets without a firm commitment basis
- Placing of digital assets with a firm commitment basis
Services 1–4 were subject to mandatory registration from 2023. Services 5–9 were subject to voluntary authorisation only under the original framework, pending MiCA implementation.
MiCA Transition
MiCA became fully applicable in France as of 30 December 2024. The French legislator and AMF established a transition framework:
- Existing registered PSANs may continue to operate under their PSAN registration during a transitional period (up to 18 months from MiCA’s application date, expiring no later than 1 July 2026)
- Entities seeking to continue operating after the transition must obtain a MiCA CASP authorisation from the AMF
- New entrants since MiCA’s application date must obtain CASP authorisation directly, without the option to register as a PSAN
PSAN-registered entities generally have a streamlined pathway to CASP authorisation, with the AMF applying a proportionate review process that credits prior registration compliance work.
Notable Registered PSANs
As of early 2024, the AMF’s PSAN register included more than 100 registered entities, including Binance France, Coinbase France, Crypto.com, Kraken, Bitstamp, and numerous French fintech and startup operators. Several PSAN registrations were refused or withdrawn due to AML/CFT deficiencies, demonstrating the AMF’s active supervisory posture.
The AMF’s scrutiny of Binance’s PSAN registration — which was ultimately granted in 2022 after an extended review — was widely covered and highlighted regulators’ concerns about large exchange operators’ AML controls.
Significance
France’s PSAN framework provided an early model for the MiCA CASP licence, influencing MiCA’s design through French participation in EU legislative negotiations. The AMF’s experience supervising a large population of PSANs — including conducting on-site inspections, processing mystery shopping exercises, and issuing public warnings about non-registered entities — contributed directly to ESMA’s developing supervisory guidance for MiCA.
Related entries: MiCA, KYC/AML in Tokenization, Travel Rule
Primary sources: AMF PSAN Register | MiCA Regulation — EUR-Lex