Stablecoins under French GAAP: separating conversion, transfer and network fees
On 5 November, a French company buys EUR100,000 of stablecoins to pay a supplier. The provider statement shows a EUR400 “fee”, followed by a EUR25 network cost in the wallet. Two weeks later, the company converts the remaining balance back into euros. The provider retains another EUR350 and the wallet shows a final EUR18 network cost. Posting all four amounts to one “crypto fees” line would break the link between each cost, the event and the supporting evidence.
ANC Regulation 2026-01, endorsed in August 2026 and published in the French Official Journal on 3 September 2026, introduced crypto-asset rules into the French General Chart of Accounts, or PCG. It does not prescribe one treatment for every amount labelled a fee. The analysis starts with the right held and the event to which the cost relates.
Identify the crypto-asset before classifying the cost
The PCG distinguishes electronic money tokens recorded in account 513 from other crypto-assets and similar items that may fall within account 522 or the accounting treatment applicable to the underlying rights. Before analysing a commission, the company should document the token, issuer, redemption right and intended use.
This prevents the account 522 rule from being applied automatically to an electronic money token or a right to receive goods or services. Article 619-10 expressly requires ancillary costs incurred when crypto-assets are first recorded in account 522 to be expensed by nature. That provision does not, by itself, classify every later cost.
The closing file should retain the provider agreement, purchase or conversion confirmation, wallet statement and invoice. These records separate amounts charged by the provider from amounts charged by the network.
A conversion fee pays for an exchange
A conversion fee relates to exchanging one asset or currency for another. It may be an explicit commission or a spread embedded in the quoted rate. The absence of a commission line does not make the exchange free.
For account 522, Article 619-15 governs the calculation of gains and losses on disposal. Article 619-16 addresses exchanges and requires the company to record the crypto-assets surrendered and the assets received. Those provisions require support for the price or value and the disposal result. They do not remove the need to identify the provider’s remuneration separately.
The working paper should reconcile the quantity surrendered, quantity received, transaction time, rate, displayed commission and final bank amount. If the provider supplies only a net amount, the accountant should reconstruct only verifiable components and should not invent an undocumented fee.
A transfer fee pays the provider
A provider may charge for sending, withdrawing, safeguarding or internally approving assets, or for access to its service. The charge may be fixed, proportional or included in a package. It is not necessarily the amount recorded on-chain.
The accountant should read the tariff and invoice: who is charging, for which service and at what point? A platform withdrawal fee may include a margin or a fixed tariff distinct from the network cost it incurred. Its commercial label does not establish that it is a network fee.
Where a subscription bundles several services, the company should allocate the amount only when the agreement or reliable information supports that allocation. Otherwise, the file should retain the nature of the service actually purchased and record the evidence limitation.
A network fee belongs to the technical transaction
A network fee is paid to have a transaction recorded or executed on the relevant ledger. It may be settled in an asset different from the stablecoin transferred. A stablecoin transfer on Ethereum may consume ether; another network may use a different mechanism and asset.
The wallet or explorer can provide the transaction identifier, addresses, time, fee asset and amount. That technical evidence establishes a network deduction. It does not, on its own, establish the accounting purpose, link to an invoice or business character. The file must connect the transaction to the underlying economic event.
The company should also determine whether the provider pays the network cost and recharges the customer. A customer statement may then show a service charge while the blockchain shows an aggregated provider transaction. The two records describe different levels and should not be confused.
Numerical case: reconcile EUR793 without merging it
Assume that the purchase is EUR100,000. The platform charges EUR400 for the initial conversion; transferring the tokens to the wallet consumes EUR25 of the network asset. On exit, the conversion fee is EUR350 and the preceding transfer consumes EUR18. The total is EUR793.
The calculation EUR400 + EUR25 + EUR350 + EUR18 = EUR793 verifies the total but does not justify a single posting. The reconciliation matrix has four lines showing the event, provider or network, asset or currency deducted, evidence, related transaction and accounting conclusion. It also checks that the same cost has not been included both in the provider’s net amount and in a separate invoice.
The final treatment depends on the crypto-asset, date and nature of the cost. For initial recognition of an asset in account 522, the requirement to expense ancillary costs by nature is explicit. In other situations, the company must apply the PCG rules relevant to the rights and transaction rather than deriving a general treatment from the word “fee”.
Conclusion
Accounting should not ask where to post stablecoin fees before identifying the event. It should first separate the exchange, the provider service and the technical network execution. Reconciliation of the EUR793 gives each amount evidence, a transaction and a rationale; it exposes net amounts, costs embedded in rates and possible double counting.
Further reading
Sources
Official sources reviewed on 4 November 2026. The numerical case and matrix are BECTRA analysis.
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