The taxman, long range version. The Senate is examining this Tuesday, October 27 from 2:30 p.m. the bill which authorizes France to approve CARF, the OECD agreement on the automatic exchange of crypto data. The principle is contained in one sentence. Platforms around the world will declare their customers to their own tax authorities and the files will end up in each person's country of residence.
The calendar has humor. The deputies are in fact resuming examination of the 2027 budget on the same day. They are expecting a tax on conversions to stablecoins and the obligation to declare large wallets. Bercy will soon have the data and perhaps the rules to use it.
CARF explained without tax jargon
The mechanism already exists for your bank accounts. Since 2017, the OECD Common Reporting Standard (CRS) has required foreign banks to report non-resident accounts. A French person who keeps an account in Geneva is known to the DGFiP without having asked anyone.
The system is based on reciprocity. France sends to Berne what it knows about the accounts of Swiss residents in France and Switzerland returns the favor. Each country only speaks to its tax owner, who then sorts by tax nationality.
Cryptos escaped this net. An exchange based in Singapore is not a bank and the account that a Frenchman opened there did not appear in any file. The OECD therefore published the Crypto-Asset Reporting Framework (CARF) in 2022, the same logic applied to digital assets.
Each service provider concerned collects the identity of its customers and their tax residence. It then declares for each crypto the number of operations and their total value over the year. Purchases against euros or dollars, exchanges between cryptos and outgoing transfers are included in the statement.
What exactly the Senate is voting on this Tuesday
Bill No. 921 consists of two articles. The first authorizes the approval of the multilateral agreement on CARF, signed by France on November 26, 2024 in Asunción with 48 other states and territories. The second concerns an addendum to the banking agreement which circulates account data since 2016 income.
Why should Parliament get involved? Article 53 of the Constitution requires the green light for this type of international commitment, and without it France cannot activate trade. However, the senators will not rewrite anything. An international agreement cannot be amended in Parliament. It is approved or rejected en bloc, here after thirty minutes of speaking time divided between the groups.
A tight schedule
The government initiated the accelerated procedure as soon as the text was tabled on July 27. The examination is therefore limited to one reading per room. The Finance Committee adopted it without modification on October 21, based on report no. 83 by Senator Emmanuel Capus.
Just before, the hemicycle examines the amendment to the France-India tax convention of 1992. India is one of the four jurisdictions which have made no commitment on the CARF, with El Salvador, Georgia and Vietnam. A process is underway with New Delhi, according to the report.
The text will then go to the National Assembly. Its legislative file does not yet set a date for examination.
DAC8 for Europe and CARF for the rest of the world
In the European Union, collection has already started. Since January 1, 2026, crypto platforms established in the EU have recorded your data under the DAC8 directive, transposed by the finance law for 2025. The first declaration to the DGFiP will relate to transactions from 2026. DAC8 is in reality the European version of the CARF. Both texts require the same data, but DAC8 only applies between the 27 Member States.
CARF exports this device outside Europe. The Capus report lists 77 jurisdictions committed to applying it by September 14, 2026, according to a schedule spread over three years.
46 jurisdictions for first exchanges in 2027, including France
27 in 2028, including Switzerland and Singapore
4 in 2029, including the United States, committed without having signed the multilateral agreement
Japan and the United Kingdom are among the 56 signatories to the agreement. However, the signature does not trigger anything on its own. “Signing the agreement alone is therefore not enough to automatically make trade operational,” writes the rapporteur, and each pair of countries must still activate their own.
France will also set its conditions. An annex will specify its data protection requirements and jurisdictions that do not comply with them will receive nothing. Emmanuel Capus made this response in committee to Senator Nathalie Goulet, worried after the data leak that occurred at the DGFiP.
The banking precedent in figures
On the banking side, France received information in 2025 on 11.6 million accounts held abroad. Their cumulative balances reached 456 billion euros, coming from 109 jurisdictions. The first campaign, ten years earlier, had 1.16 million.
For cryptos, the expected volume remains “difficult to assess at this stage” according to the rapporteur. Adan estimated at the beginning of 2025 that 10% of French adults held crypto-assets, worth 21 to 26 billion euros.
What actually changes for a French holder
It all depends on where your cryptos are sleeping. Four situations cover the majority of holders.
European platform. You buy on an approved exchange in France or elsewhere in the EU. DAC8 already transmits your 2026 operations and CARF does not add anything.
Swiss or Singaporean platform. Your 2027 operations will go to the local administration, which will relay them to the DGFiP in 2028 with your name, address and tax number.
American platform. The United States will only exchange data from 2028 from 2029.
Wallet for which you hold the keys. No intermediary, therefore no automatic declaration. Courson's amendment would create a simple declaration obligation above 100,000 euros, without additional tax.
In each case, the tax authorities receive the statement within nine months following the end of the year concerned.
Your obligations do not change. Any digital asset account opened abroad must already appear on form 3916-bis, under penalty of a fine of 750 euros per forgotten account. The bill increases to 1,500 euros when the value of the accounts exceeds 50,000 euros in the year.
For the record, 3916-bis indicates the existence of an account. Form 2086 calculates the tax on your capital gains. These are two separate statements, and CARF allows you to verify both.
What changes are the means of control. The DGFiP will be able to cross-check the accounts declared and the capital gains reported on form 2086 with the flows sent by the platforms themselves. An account opened in Zurich and forgotten on 3916-bis will appear in the files received in 2028.
Self-hosted wallets remain outside the system. Without an intermediary, no one declares anything to anyone. This is precisely the hole that the 2027 budget wants to plug.
The 2027 budget writes the rest
CARF provides the data. The rules of taxation are currently being played out in the National Assembly. The finance committee rejected the revenue part of the finance bill on October 9, so that the hemicycle starts again with the government's copy.
The flat tax of 31.4% on crypto capital gains is not changing. No amendment has touched it.
The tax on stablecoin conversions
Stablecoins are the focus of the battle. Adopted in session on October 16 by 38 votes to 37, the amendment by MP Nicolas Sansu (GDR) makes the conversion of a crypto into a stablecoin taxable from January 1, 2027. Today, switching from bitcoin to USDC does not trigger any tax as long as you do not return to euros. Exchanges between cryptos benefit from a tax deferral, and only the exit to the official currency or the purchase of a good is taxed.
With this text, a capital gain of 40,000 euros released in stablecoin would cost 12,560 euros. It only targets electronic money tokens within the meaning of MiCA, i.e. stablecoins backed by a single currency and approved in Europe. This definition would leave USDT, which does not have any MiCA approval, out of scope.
Unhosted wallets and exit tax
Charles de Courson (LIOT) returns with the declaration of unhosted portfolios beyond 100,000 euros held as of December 31. The obligation is purely declarative. It does not create any tax and serves to notify the tax authorities of the existence of the portfolio. An oversight could cost up to 10,000 euros in fines. Two versions of an exit tax are also on the table. The principle consists of taxing your unrealized capital gains on the day you leave France, even if you have not sold anything. That of Nicolas Sansu targets holders of more than 800,000 euros of cryptos, the other is supported by the socialist group.
The government text finally provides for a fine of 10,000 euros per request. It targets platforms which refuse to transmit their documents to the tax authorities. Everything depends on the solemn vote on the revenue side. The debates must end on Monday November 2 and the vote is recorded on Tuesday November 3 afternoon in the Assembly. But a rejection would bring the whole thing down. This is what happened on October 23 to the revenue part of the Social Security budget, swept away by 115 votes to 1.
For France, the first CARF exchanges are planned for 2027 with the 45 other jurisdictions of the first wave. They will cover the year 2026, and your operations over the last ten months are already included in the scope.
