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Stablecoins under French GAAP: what ANC Regulation 2026-01 changes

2 hours ago
2 min read

A French company receives stablecoins in settlement of an invoice. The tokens trade close to one unit of currency. Should the company therefore treat them as a bank balance? The starting point is to identify the token and the accounting rules applicable to the reporting period.

 

ANC Regulation 2026-01 introduces a specific treatment for e-money tokens. Its effective date matters: describing a new account without explaining the transition would leave readers with an incomplete picture.

 

An endorsed regulation with a defined transition

 

Established rule. Adopted on 9 January 2026, the regulation was endorsed by an order dated 12 August and published on 3 September 2026. Article 9 requires application for financial years beginning on or after 1 January 2027 and permits early application for the financial year in progress at publication. [ANC26]

 

For a calendar-year 2026 reporting period, the company’s early-application decision therefore matters. The publication year of an article alone does not determine the rules used in its accounts.

 

Distinguishing a custodian’s aggregate balance from client rights.

 

BECTRA illustration — Distinguishing a custodian’s aggregate balance from client rights.

 

Before applying the reform: consider the existing framework

 

The PCG consolidated at 1 January 2026 distinguishes tokens with financial-instrument characteristics and, for other tokens, the intended use of associated goods or services. Former Article 619-12 provides for account 522 where those goods or services are not intended to be used. [PCG26]

 

Interpretation requiring support. Applying that branch to a particular stablecoin requires an assessment of its characteristics. Account 522 should not become the automatic answer for every asset marketed as a stablecoin.

 

The reform provides a specific route for EMTs

 

New Article 619-8.2 assigns MiCA-defined e-money tokens to account 513 and refers to Article 420-7 for closing measurement. Financial instruments and other crypto-assets follow separate branches. [ANC26]

 

MiCA defines an EMT by reference to a single official currency. Article 49 provides, among other things, a holder’s claim and redemption at par. [MICA] The asset must be shown to meet the relevant category. A dollar label is insufficient evidence.

 

Distinguishing quantity, token parity and currency conversion.

 

BECTRA illustration — Distinguishing quantity, token parity and currency conversion.

 

Legal rights and practical access are separate questions

 

BECTRA analysis. Distinguish the token’s classification from the company’s position. Does it hold the token directly or a contractual position against an intermediary? Can it exercise the rights relied upon? Custody and redemption terms help establish the facts.

 

Consider a fictional example: two companies each see “10,000 units” in an interface. One directly holds an identified EMT; the other has a service provider’s promise to return tokens. Similar screen displays do not establish identical assets.

 

Conclusion

 

First identify the accounting regime applicable to the reporting period, then examine the rights attached to the position. Account 513 is a specific development; it does not remove the need to establish what the company actually holds.

 

Further reading

 

 

 

 

Sources

 

Sources reviewed on 19 October 2026. Examples are fictional; BECTRA analysis is distinguished from applicable rules.

 

 

 

 

 

 
 
 

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