Bercy, new trader in your portfolio. Since June 26, 2026, the tax administration can seize the cryptos you leave on a platform and force it to sell them to pay off a tax debt.
The measure is contained in an article of the law against social and tax fraud, which remained discreet until the formula circulated on X this Tuesday. It falls on the day the Senate is considering CARF, the agreement which organizes the automatic exchange of your crypto data between states.
Key Points
Article 90 of Law No. 2026-534 opens administrative seizure to third-party holders of crypto-assets kept by a service provider.
The taxpayer first has the hand to sell, then the platform sells for him.
All positions in the account can be transferred there, up to the amount claimed.
Self-custody wallets are not covered by this mechanism.
The deadlines remain suspended by a decree.
What Article 90 says about seizing your cryptos
The text is called Law No. 2026-534 of June 25, 2026 relating to the fight against social and tax fraud. It appeared in the Official Journal on June 26.
Its article 90 adds a paragraph 2 bis to article L. 262 of the Book of Tax Procedures. This article governs administrative seizure by third party holder (SATD), the tool which allows the Public Treasury to use it directly from your bank or your employer, without going through a judge.
The novelty targets crypto-assets “kept by a service provider”. The seizure applies “indifferently to the entire portfolio” held on the day it falls, within the limit of the amount due. Bitcoin, ether or evenmecoin forgotten, the tax authorities do not sort it out.
You keep control first. The taxpayer can sell his assets himself within a period fixed by decree.
After this period, the platform sells on your behalf, if it is authorized to do so, and pays the tax authorities the proceeds of the sale in euros or foreign currencies. Otherwise, she entrusts the operation to a service provider who is. The sale entails immediate allocation of funds to the Treasury, on the date of notification of the seizure.
Platforms will not be able to charge more than banks. Their costs are capped at 10% of the amount due, within the limit of a ceiling set by decree. The system has been in force since the publication of the law, with a transition to the MiCA vocabulary of “crypto-assets” on July 1, 2026, according to the text of article 90 published on Légifrance.
Why Bercy couldn't seize your bitcoins before
The measure comes from an amendment tabled on December 10, 2025 and adopted in committee. It is carried by the deputy Daniel Labaronne, rapporteur for the opinion of the Finance Committee.
His statement of reasons poses the legal problem. Crypto-assets “are neither comparable to legal tender nor to debts for sums of money”. The SATD could therefore not reach them, and a forced sale was the responsibility of the justice commissioners.
Hence the conclusion of the deputies: “Their sale is therefore a necessary prerequisite” for recovery. Amendment AS596 justifies the measure by the risk of cryptos being used to hide taxes. However, he does not put forward any fraud figures.
The same article 90 hardens a second point. If you do not declare a crypto account opened abroad, the tax authorities now have ten years to claim the registration fees and the IFI concerned, as for a bank account or a hidden trust.
What escapes the seizure of cryptos
The text only covers assets kept by a service provider. The cryptos that you hold in self-custody, on a wallet for which only you have the keys, exit this mechanism and remain subject to traditional execution procedures.
The old bitcoiners adage takes on an unexpected meaning. Not your keys, not your cryptos.
Several areas remain unclear. Lawyer Stéphanie Némarq-Attias, from the Qomit law firm, questions the application to platforms established outside France and the articulation with international recovery assistance.
The two deadlines provided for in 2 bis refer to a decree. We have not found it in the Official Journal to date.
There remains one spicy detail. A conversion of cryptos into euros is in principle a taxable event under article 150 VH bis of the CGI. A forced sale to pay tax can therefore create a capital gain to be declared the following year.
