Skip to content
Regulation

France's €100K Self-Custody Rule: What Amendment I-CF821 Actually Requires

France's National Assembly Finance Committee backed annual declarations for self-held crypto wallets worth €100,000 or more, with fines up to €10,000. Here is the text, the tax gap it cites, the security backlash, and why it is not law yet.

By BtcMedia Labs Research · · 6 min read

Table of contents
  1. What the amendment would require
  2. The €3.1 billion gap the sponsors cite
  3. Not France’s first try—and not yet on the floor text
  4. Companion crypto amendments in the same package
  5. Why the security backlash is loud
  6. What this is—and is not
  7. What to watch next

If you hold your own keys in France and your self-custody wallets are worth €100,000 or more on December 31, a National Assembly Finance Committee amendment would make you declare them every year—or risk a fine of up to €10,000. The measure, Amendment I-CF821 to the 2027 finance bill, passed committee on October 9, 2026. It is not law. Hours later the same committee rejected the budget’s revenue section, so the full Assembly starts from a government text that does not include the crypto amendments unless lawmakers table them again.

The proposal is still the story that is moving on X this week. CoinMarketCap recirculated the €100,000 / €10,000 headline overnight, and X’s own news brief framed the same tension: tax transparency versus fear of wrench attacks in a country already logging crypto-linked kidnappings (X story). This piece sticks to what the amendment says, what the sponsors cite as the tax gap, and what still has to happen on the floor.

What the amendment would require

I-CF821 was filed on October 3 by deputies Charles de Courson, Jean-Pierre Bataille, and Michel Castellani (LIOT group). According to the official Assemblée nationale text and reporting by Crypto Briefing and Chain Daily:

  • It inserts a new paragraph into article 1649 bis C of the general tax code.
  • Persons and legal entities already covered by that article would also have to declare crypto-asset portfolios they hold directly.
  • The duty applies when those portfolios are not kept with a crypto-asset service provider (in other words, self-custody).
  • The valuation date is 31 December of the year the declaration covers.
  • The threshold is a total value of €100,000 or more.
  • A second limb updates article 1729 C ter so that non-declaration can be sanctioned; the authors say the fine can reach €10,000.

Regulated platforms already sit inside reporting regimes. Self-custody has largely sat outside that net. The amendment is designed to close that gap for large holders—not to invent a new tax rate on unrealised gains.

The €3.1 billion gap the sponsors cite

The explanatory note does not hide the motive: under-declared crypto and fraud risk. Sponsors point to a parliamentary inquiry into the taxation of large fortunes and high incomes. That inquiry’s figures, as summarised in the amendment materials and by Crypto Briefing, put €3.5 billion of crypto capital gains realised in 2021 against only about €400 million of holdings declared to the French tax administration (DGFiP) that same year—a paper gap of roughly €3.1 billion.

Those are historical inquiry numbers, not a live audit of 2026 wallets. Still, they explain why fiscal drafters want a list of large self-held portfolios: if the administration knows a wallet exists above the line, undeclared disposals become harder to ignore.

Not France’s first try—and not yet on the floor text

An earlier 2026 proposal set the declaration bar at just €5,000. Lawmakers rejected that lower threshold in April. The new figure is twenty times higher. Coverage from Crypto Briefing links the jump partly to security concerns: a narrower pool of large holders, fewer ordinary users forced into a registry.

Procedurally, committee adoption was not enough. Later on October 9 the Finance Committee rejected the 2027 budget’s revenue section by 31 votes to 3. Per Chain Daily and Decrypt, the full National Assembly therefore resumes revenue debate from the government’s original draft—which contains none of the committee’s crypto amendments. Backers must re-table I-CF821 (and companion measures) on the floor. A formal revenue vote has been discussed around 20 October; that calendar can still slip.

Companion crypto amendments in the same package

I-CF821 did not travel alone. Chain Daily reports the committee also waved through related ideas that matter for anyone modelling a French tax calendar:

  • Treating a swap into an electronic money token (MiCA’s stablecoin category) as a taxable sale from 1 January 2027, with gain measured against the original cost basis and taxed under France’s flat tax (raised to 31.4% from January 2026 after social charges rose).
  • Extending France’s exit tax to crypto for moves abroad from 1 January 2027 where a tax household’s combined holdings exceed €800,000 and the taxpayer has been resident for at least six of the previous ten years.
  • Allowing crypto loss carry-forwards for ten years, parallel to shares.

None of these are law either. They share I-CF821’s fate: re-file or die with the rejected revenue block.

Why the security backlash is loud

The disclosure fight is not only about privacy abstractly. France has become a hotspot for physical attacks on crypto holders. Cointelegraph Magazine, citing Interior Ministry figures, reported 90 crypto-linked cases of kidnapping, abduction, extortion, threats, and violent theft from 1 January to mid-August 2026, plus 223 arrests and 126 imprisonments (January–July). High-profile cases covered by Decrypt include the 2025 kidnapping of Ledger co-founder David Balland, an attempted kidnapping of The Sandbox co-founder Sébastien Borget’s wife, and a Versailles knifepoint transfer of about $1 million in bitcoin.

Critics connect that violence to data leaks. Decrypt quotes Nym CEO Harry Halpin pointing to a French tax official accused of selling taxpayer data, and Zama founder Rand Hindi writing on X that if you live in France and hold crypto, leave—or hire security. Accounts amplifying the amendment on X, from Learning Crypto to allthemoney, repeatedly pair the €100,000 threshold with wrench-attack risk. A government list of wealthy self-custody holders is, in that framing, a targeting database if it leaks.

Sponsors answer that the higher threshold was meant to reduce that surface area relative to the failed €5,000 draft. Opponents answer that any mandatory ledger of large holders still concentrates risk.

What this is—and is not

A few distinctions keep the story accurate:

  • Not law. Committee text is gone from the floor vehicle until re-tabled.
  • Not a ban on self-custody. The proposal is a declaration duty above a high bar, not an order to use custodians.
  • Not a new capital-gains rate. It is about who tells the tax office that a large self-held wallet exists.
  • Not advice to leave France or move coins. Reactions on X are part of the political debate; they are not investment or migration guidance.

For most French users below €100,000 of self-held crypto, the immediate legal effect of I-CF821—even if revived—would be zero. For large holders, the open questions are whether the threshold survives floor debate, how declarations are stored and secured, and how companion exit-tax and stablecoin-swap rules interact if any of them return.

What to watch next

Watch whether I-CF821 (or a rewrite) is re-filed when the Assembly finishes the revenue section, whether the €100,000 line holds or drifts back toward a lower figure, and whether exit-tax and stablecoin-swap amendments ride along. Outside the chamber, watch Interior Ministry crime tallies and any further disclosures about tax-data breaches—the security argument will shape the politics as much as the €3.1 billion tax-gap argument shapes the fiscal case.

France is trying to see large self-custody balances the same way it already sees exchange accounts. Crypto holders are asking whether that visibility is worth the physical risk in a country that has already documented dozens of crypto-linked violent crimes this year. The committee opened the door; the floor still has to decide whether to walk through it.


This article is for informational purposes only and is not financial, legal, or tax advice. Cryptoassets are volatile; regulation can change. Do your own research.

Share XLinkedInWhatsAppTelegram
BL

BtcMedia Labs Research

The research desk at BtcMedia Labs. We read the primary sources — whitepapers, statutes, ETF flow data and on-chain dashboards — so you can make up your own mind. Every number we publish links to where it came from.

Keep reading

Regulation

Regulated Rails: South Korea and Russia Push Crypto Trading Onshore

In one week, South Korea moved to block 27 unregistered exchange websites and got its first bitcoin-backed bank loan, while the Moscow Exchange set a December 1 target for retail spot crypto. The common thread is steering users toward venues regulators can see.

· 5 min read

Regulation

Coins.ph Under the Microscope: What the BSP Action on DCPay Means for Philippine Crypto

The Philippines' largest crypto exchange is reportedly facing central bank action over alleged offshore gambling flows, after the BSP froze inbound peso transfers to its e-wallet arm DCPay. Here is what is confirmed, what is still a claim, and why it matters for 18 million users and the remittance corridor.

· 5 min read

The Block Height Brief

One sharp crypto briefing, every Sunday.

Markets, policy and on-chain signals — sourced, no shilling.

⚠ Placeholder form — not connected to an email provider. No data is sent or stored.