What accounting treatments apply under French GAAP?
On 7 November, a French company buys EUR 200,000 of euro-referenced tokens to pay a supplier. Before selecting an account, its finance director needs four documented answers: is the token an electronic money token under MiCA, what enforceable right does the holder have, why will the company hold it, and which accounting regulation applies to the reporting period? If that analysis is skipped, a one-euro price target can be mistaken for evidence that the token is cash.
Start with the token’s legal nature
ANC Regulation 2026-01 recast the French General Chart of Accounts provisions for crypto-assets. Its scope covers crypto-assets defined by MiCA and certain comparable items using distributed ledger technology.
For a holder, the first branch covers assets with the characteristics of financial securities, promissory notes or financial contracts. Article 619-8 directs the entity to the accounting rules for the corresponding instrument. The second branch covers electronic money tokens, which MiCA defines as crypto-assets that purport to maintain a stable value by referencing one official currency. These tokens are recorded in account 513 and measured at the reporting date under Article 420-7.
The commercial label “stablecoin” is therefore insufficient. The file should reconcile the white paper, redemption terms, issuer identity and any restrictions affecting the holder. A dollar-referenced token that does not have the legal status of an electronic money token does not automatically belong in account 513.
Intended use affects the accounting category
For other crypto-assets, Article 619-9 requires the entity to identify the attached rights and its intention to use them in its operations. When a token gives access to an asset or service and the entity intends to exercise that right, accounting follows the substance of the right: an intangible asset, tangible asset, inventory or prepaid expense, as applicable.
Otherwise, Article 619-10 requires account 522, “Crypto-assets and comparable assets held”. This branch includes a token that does not represent a right to an asset or service and a token whose intended use remains undetermined on initial recognition. Related transaction costs are expensed according to their nature.
Management should not rewrite this analysis later to achieve a preferred result. A classification memo dated at acquisition should identify the decision, the evidence reviewed and the person who approved it.
Keep the 2026-2027 transition visible
ANC Regulation 2026-01 is mandatory for financial years beginning on or after 1 January 2027. It may be applied early to the financial year in progress when the regulation was published in the French Official Journal. A reporting date in 2027 does not determine the answer by itself: the opening date of the financial year and any early-adoption decision matter.
A calendar-year company should state whether it elected early adoption for 2026 and must apply the new text for 2027. For an off-calendar year beginning on 1 October 2026 and ending on 30 September 2027, mandatory application does not begin automatically in January 2027 because that financial year began before the effective date.
Worked case: 200,000 tokens do not necessarily equal EUR 200,000 of cash
Assume that three lots are acquired on the same day:
• 120,000 electronic money tokens redeemable at their monetary value;
• 50,000 tokens giving access to cloud services that the company will consume over twelve months;
• 30,000 tokens with no identified right to an asset or service, held pending a management decision.
Under ANC Regulation 2026-01, the first lot is recorded in account 513, subject to documented legal qualification. The second follows the underlying service right and may lead to a prepaid expense. The third generally falls within account 522. The entity should not present all three lots as a single cash balance.
The practical deliverable is a lot-by-lot matrix showing the token identifier, issuer, enforceable right, intended use, proposed account, measurement rule, supporting source and approving manager. It should reconcile to the wallets, subledger and general ledger.
What French GAAP does not replace
The French General Chart of Accounts governs French statutory accounts. It does not replace the IFRS analysis for consolidated reporting, the prudential rules applicable to banks, or the MiCA duties of issuers and service providers. The same holding may therefore require a French GAAP conclusion for statutory accounts and a separate conclusion for group reporting.
Our article on classifying stablecoins under IFRS explains that boundary. For the first application of the French rules, see Stablecoins and the French GAAP 2026-2027 transition.
Conclusion
French GAAP treatment begins with the holder’s right and management’s intended use, followed by the regulation’s effective date. Account 513 is not a general category for every stable token, and account 522 is not a substitute for analysis. A defensible file connects legal qualification, intended use, measurement and proof of ownership for each lot.
Further reading
BECTRA recommends retaining the classification matrix, archived contractual terms, evidence of intended use, the quantity reconciliation and the memo identifying whether the 2026 or 2027 regime applies. A change in redemption rights or intended use should trigger a new review while preserving the original recognition decision.
Sources
• Autorité des normes comptables, “ANC Regulations 2026-01 and 2026-02 of 9 January 2026”, published 18 February 2026 and updated 7 September 2026: https://www.anc.gouv.fr/reglements-anc-ndeg2026-01-et-anc-ndeg2026-02-du-9-janvier-2026
• Légifrance, Order of 12 August 2026 endorsing ANC Regulation 2026-01, French Official Journal: https://www.legifrance.gouv.fr/eli/arrete/2026/8/12/ECOT2617843A/jo/texte
• European Union, Regulation (EU) 2023/1114 of 31 May 2023 on markets in crypto-assets, notably Article 3: https://eur-lex.europa.eu/eli/reg/2023/1114/oj
Comments