France wants to tax stablecoin swaps and report large wallets

Amendments in the 2027 budget

The National Assembly is considering two amendments to the 2027 budget. They cover swaps into e-money tokens and reporting for large self-custody wallets. Both texts are proposals in an ongoing bill.

No statute has been passed.

The texts are on the Assemblée nationale site, attached to finance bill no. 3210. The law firm ORWL Avocats sums up the file as of 12 October. That is the firm’s account, not a vote record printed on the amendment pages.

Swaps into e-money tokens

Nicolas Sansu, of the Gauche démocrate et républicaine, filed I-CF1826 on 4 October with 16 other deputies. The finance committee examined it on 7 October. ORWL writes that the committee adopted it.

The same text is back for the public sitting as I-3898, filed again on 10 October by Sansu and his group. Mickaël Bouloux, of the Socialistes et apparentés, filed I-3680 the same day in support. I-3680 amends the existing paragraph on how a gain is computed. I-3898 rewrites the section.

The practical result in both texts is the same. Swaps that end with the seller receiving an e-money token drop out of the tax deferral in article 150 VH bis of the code général des impôts. So do rights attached to those tokens. The citation is article 3(1)(7) of the MiCA regulation: a token that references a single official currency.

The explanatory note talks about stablecoins tied to a fiat currency. On Solana, USDC and EURC sit in that group. A stablecoin without that peg is not carved out of the deferral.

The rule would apply to disposals and swaps from 1 January 2027. The amendments do not set a new rate. The explanatory note puts the gain under the existing flat tax, the prélèvement forfaitaire unique. The gain is the amount in question. The size of the swap is not a separate tax base.

Acquisition cost would become the weighted average for crypto-assets of the same kind. For holdings acquired before 1 January 2027, the text offers a choice. A filer can use the actual price of each asset, with records. Or the filer can spread the portfolio’s total acquisition cost as of 31 December 2026 across the holdings that day, in proportion to their value.

The choice covers the whole portfolio and cannot be reversed. It is made on the first return that mentions a taxable disposal after 1 January 2027.

In the explanatory note, the sponsors write that the United Kingdom and Italy have already legislated in this direction. That sentence is their argument.

Daniel Grenon filed the opposing amendment I-3738 on 10 October. It would write the deferral into the statute for swaps with no cash balancing payment between crypto-assets and e-money tokens, in both directions.

Reporting from 100,000 euros

Charles de Courson, of Libertés, indépendants, outre-mer et territoires, filed I-CF821 on 3 October with Jean-Pierre Bataille and Michel Castellani. The finance committee examined it on 9 October. ORWL writes that the committee adopted this amendment as well.

De Courson refiled the text for the plenary on 10 October as I-2701, with further deputies. The page says the Assembly’s services are still processing it and that admissibility is still open.

The amendment adds to article 1649 bis C. Persons and legal entities already named in the first paragraph would also declare crypto portfolios they hold directly and that are not kept with a crypto-asset service provider. The duty applies when those holdings are worth at least 100,000 euros on 31 December of the year covered by the return.

Direct holding means the owner keeps the keys. On Solana that includes Phantom, Solflare, or a hardware wallet. The amendment does not name those products.

The figure of up to 10,000 euros is in the explanatory note, for a missing declaration. The new paragraph points to article 1729 C ter of the code général des impôts. For 2021, the note sets realized gains of 3.5 billion euros against 400 million euros of holdings declared to the DGFiP. The sponsors cite an inquiry commission for those two figures.

On 10 October Sansu filed two further reporting duties for the plenary. They carry the same note that processing and admissibility are still open. I-3922 requires an annual report of market value once a self-custodied portfolio holds more than 5,000 euros. I-3923 is the fallback, with the line at more than 50,000 euros. Deadlines and details are left to a decree.

The sitting, then the Senate

ORWL dates its account to 12 October. By then the finance committee had adopted five crypto amendments, including I-CF1826 and I-CF821. As of that date, none of them had been adopted in the public sitting.

On a finance bill the plenary debates the government’s text, not the committee text. That is why the amendments were filed again under new numbers. ORWL cites the schedule set by the conference of presidents on 29 September. Under that schedule the public sitting on the revenue side runs from 13 to 19 October. The solemn vote on the first part is set for 20 October.

That date is the frame for the first part of the budget. The schedule does not show that these particular amendments will be called on a given day. After the National Assembly, the bill goes to the Senate. The rules change when a statute is promulgated.

What to watch

Whether the plenary adopts I-3898, I-3680, or the opposing amendment I-3738
Whether I-2701, I-3922, and I-3923 are ruled admissible
Whether the 100,000 euros is counted per wallet or across all self-custodied holdings
Whether the Senate follows a vote of the National Assembly

Sources

Assemblée nationale — I-CF1826, filed 4 October 2026, finance committee 7 October 2026 · I-3898, 10 October 2026 · I-3680, Mickaël Bouloux, 10 October 2026 · I-3738, Daniel Grenon, 10 October 2026
Assemblée nationale — I-CF821, filed 3 October 2026, examined 9 October 2026 · I-2701, 10 October 2026, admissibility note · I-3922, threshold above 5,000 euros · I-3923, threshold above 50,000 euros
ORWL Avocats — Analysis as of 12 October 2026. Committee adoption, plenary numbers, schedule of the conference of presidents of 29 September 2026