France (FR)

Licensing, Authorisation & Market Access

France's eighteen-month MiCA transitional period for legacy PSAN closed on 30 June 2026; from 1 July 2026 only MiCA-authorised CASPs may lawfully provide crypto-asset services in France, with non-compliance carrying up to two years' imprisonment and a €30,000 fine under the Code monétaire et financier. Of the roughly 117 PSAN registered with the AMF in January 2026, 83 obtained MiCA/CASP authorisation while 34 remained pending as the deadline passed. Binance is the most consequential of the unauthorised group: it confirmed on 24 June 2026 that it will not secure French MiCA authorisation, is winding down French spot trading from 1 July 2026, and will wind down margin and loan products from 1 October 2026; ESMA published wind-down guidance on 23 June 2026 to help supervise the transition of client positions away from exiting firms. Bank-PSP and non-bank PI/EMI participants sit on different sides of this authorisation line: CASP status under MiCA is a non-bank payment-institution-adjacent authorisation track, distinct from the credit-institution licensing that banks separately hold, and firms without dual payment-institution status must route certain e-money-token services through the ACPR's prudential perimeter. France transposed MiCA through Ordonnance n°2024-936 of 15 October 2024 and Décret n°2025-169 of 21 February 2025; the AMF is lead competent authority for CASPs while the ACPR supervises issuers of asset-referenced and e-money tokens and any EMT-related CASP services requiring dual payment-institution status, and roughly six CASPs appeared on the ESMA register as French-authorised at the start of 2026. A second, structurally larger change is arriving on the same licensing spine: PSD3/PSR reached provisional trilogue agreement on 27 November 2025, with compromise texts before COREPER for approval in April 2026 and Official Journal publication expected this summer, opening a 21-month national transposition window for the directive while the regulation applies directly. PSD3 folds electronic-money institutions into a single payment-institution licensing category, eliminating standalone EMD2 status and collapsing a distinction that has separated bank-adjacent e-money issuers from payment institutions since EMD2's adoption.

Outlook

France's simultaneous MiCA/CASP cliff-edge and forthcoming PSD3/PSR relicensing wave will compress the compliance calendar for French PSPs and CASPs over the next twelve to twenty-one months. Watch for Official Journal publication of PSD3/PSR, expected this summer, which starts the 21-month transposition clock, and for completion of Binance's French margin and loan-product wind-down on 1 October 2026.

Correspondent Banking, Settlement & Access

The analytical spine of this module is the bank versus non-bank access asymmetry, and this cycle delivers the most material structural change to it. Following the IPR amending the Settlement Finality Directive, the Eurosystem policy approved 17 July 2024 grants non-bank PSPs (PIs and EMIs) direct access to TARGET — T2 for settling payments and TIPS for instant payments — from 6 October 2025 under Guideline ECB/2025/28, under the same requirements as credit institutions. The accounts are settlement-only (they cannot safeguard users' funds), subject to a holding limit typically around twice the highest daily outgoing-transfer value over the past twelve months, and not eligible for Eurosystem credit; indirect participants are to transition by 31 December 2025. This is a landmark change: French PIs and EMIs can now settle directly in central bank money without a sponsoring bank, reducing dependence on correspondent access.

The asymmetry is not fully resolved. Settlement-only accounts do not solve the safeguarding-account de-risking problem. The Eurosystem notes non-bank PSPs have cited difficulties opening and maintaining accounts with credit institutions owing to bank de-risking; Article 32 of the draft Payment Services Regulation proposes measures to counter such practices, requiring any refusal or withdrawal of access to be based on serious grounds.

Outlook

PSR Article 32 counter-de-risking measures, expected in 2026, directly address the safeguarding and operating-account de-risking that constrains French non-bank PSP viability — the key forward access-rights development for the module.

Stablecoins & Digital Money

The French stablecoin supervisory architecture is split under MiCA: the AMF handles CASPs, crypto-asset white papers and market abuse, while the ACPR is competent for stablecoin provisions covering EMTs and ARTs, with EMTs assimilated to the EMD2 e-money regime. MiCA stablecoin provisions have been applicable since 30 June 2024. The dual-authority split determines which French regulator a stablecoin or CASP business must engage, and the EMT/EMD2 assimilation is the trust-as-payment-instrument anchor.

France is the EU forerunner on EMT issuance. Circle obtained an ACPR EMI licence aligned to MiCA's stablecoin provisions — which entered application 30 June 2024 — publicly announced 1 July 2024 as the first global stablecoin issuer to be MiCA-compliant, enabling its French entity to issue USDC and EURC under MiCA EMT obligations.

The policy posture is nonetheless cautious. Banque de France assesses MiCA as a vital but incomplete step, not comprehensively addressing conglomerate concentration, DeFi, or large-scale adoption of USD-denominated stablecoins issued by non-bank non-European entities, and argues central bank money must remain the primary settlement asset between intermediaries. This signals a French and Eurosystem stance against USD-stablecoin dominance that feeds the digital-euro and wholesale-CBDC sovereignty agenda.

Outlook

France's legacy PACTE PSAN regime holders must transition to MiCA CASP status by 1 July 2026, the key dated milestone for the module.

Commercial Intelligence (M&A, Investment & Product)

Qonto's application for a French banking licence, filed in 2025, is reported to be making good progress with positive regulatory feedback and a targeted approval within roughly six months as of late June 2026, a step that would let the company move beyond payment-institution scope to offer in-house credit and lending products. Its competitor Pennylane reports more than 800,000 SME customers as of mid-2026, positioning both firms for a contest over French small-business accounts as the country's mandatory B2B e-invoicing regime approaches. That regime requires receiving invoices through a registered Plateforme de Dématérialisation Partenaire in the Factur-X format from 1 September 2026, with issuing obligations phasing in for all business sizes through 2027.

Outlook

Qonto's pending banking licence, if granted within the reported roughly six-month window, would materially alter competitive dynamics among French SME neobanks by allowing in-house credit provision beyond payment-institution scope, intensifying its rivalry with Pennylane as both compete for share of the French SME market ahead of the September 2026 e-invoicing deadline.

Conduct, Safeguarding & Promotions

Safeguarding is the live W1b pressure point for French non-bank PIs and EMIs. Funds received on behalf of users must be placed in dedicated account(s) at a credit institution, separately from the institution's own funds — and the ACPR notes that some firms struggle to find a credit institution willing to provide such a segregated account. Any change to the protection method requires prior ACPR authorisation, decided by the Chairman of the College. Segregation availability is therefore a structural pressure point: bank de-risking of PI/EMI safeguarding accounts directly constrains non-bank market viability, distinct from the bank-PSP position which does not face the same external-account dependency.

Outlook

General safeguarding rules remain unchanged, but the incoming PSD3/PSR introduces an optional method of safeguarding funds in a central-bank account, with central banks not required to offer it; the ACPR is expected to update Instruction n.2019-I-22 accordingly. An optional central-bank safeguarding route could mitigate the bank de-risking problem for French PIs and EMIs if the Banque de France chooses to offer it — the key open question for this module into 2026.

Operational Resilience & Critical Infrastructure

DORA entered into application on 17 January 2025; the ACPR supervises banking, insurance and payment entities for ICT risk management, major-incident reporting, the Register of Information (with first registers expected by 15 April 2025), and ICT third-party oversight, with threat-led penetration testing conducted under TIBER-FR. DORA compliance — including incident-reporting timelines, the Register of Information, and third-party oversight — is now a live operational obligation for all French in-scope payment entities.

On critical infrastructure, the Banque de France is the designated competent authority for oversight of the CORE(FR) systemically important payment system operated by STET, and participates in cooperative oversight of other Eurosystem SIPS including TARGET2 and TIPS, EURO1, STEP2, and Mastercard Europe. CORE(FR)/STET is the critical domestic retail clearing backbone, and its oversight regime is foundational infrastructure for all French payment flows.

Outlook

No separate French national critical-third-party payments resilience statute beyond DORA and ACPR internal-control orders was identified; resilience rests on directly-applicable EU DORA plus the ECB SIPS Regulation. Overseas-territory DORA carve-outs are noted but not separately tracked this cycle.

Scheme & Network Compliance

Cartes Bancaires CB, established in 1984, is the leading French payment brand, with over 65% of household consumption paid by CB card; more than 95% of French cards are co-badged with Visa or Mastercard, enabling a choice between domestic CB routing and international scheme routing. CB does not support commercial-dispute or merchant-led fraud contestation, and PCI DSS and 3D Secure are mandatory. Co-badging and routing choice define merchant economics and acceptance strategy in France, and CB's no-commercial-dispute design differs materially from the international schemes.

On scheme economics, the EU Interchange Fee Regulation caps interchange at 0.2% debit and 0.3% credit, applicable to CB transactions; CB interchange ranges roughly 0.20%–0.90% per EU regulation, paid by the acquiring bank to the issuing bank, with PCI DSS adherence required. These interchange caps directly set merchant acceptance cost economics for card payments in France.

Outlook

The scheme and interchange picture is stable; CB co-badging and routing arrangements and the IFR caps are not in active flux, with PCI DSS and 3D Secure remaining mandatory baseline obligations.

Payment Corridor Dynamics

IBAN-name Verification of Payee checks became mandatory for SEPA Instant credit transfers in France from 9 October 2025 under the Instant Payments Regulation (EU) 2024/886. PSD3/PSR will extend the same verification obligation to all credit transfers, adding payer-PSP refund obligations for failures of the verification mechanism itself, which will bring the corridor-level anti-misdirection check already live for instant transfers into the standard credit-transfer rail as well.

Outlook

Watch for PSD3/PSR's Official Journal publication, expected this summer, which will fix the timetable for extending Verification of Payee to all French credit transfers beyond the SEPA Instant corridor.

Industry Structure & Commercial

The French payments market is bank-dominated at the acquiring and issuing layers — CB is run by major banks; the Estreem BNP/BPCE issuer-processor JV aspires to 17bn annual transactions; and Worldline is Europe's largest acquirer — but with a vigorous non-bank fintech layer including Qonto, Lydia/Sumeria, Treezor and Pennylane. The top five European processors command roughly 55% of market value. This structural concentration at the processing layer, combined with an active challenger layer, frames the competitive landscape for any operator entering France.

Outlook

The structural market view is established and stable in shape; the active interplay between bank-dominated processing incumbents and the non-bank challenger layer remains the analytical spine for this module, with specific deals and rounds tracked separately under W13.

Legal & Litigation

The ACPR's disciplinary powers are split between the College (prosecution) and the Sanctions Committee (a judicial body chaired by a Conseil d'État member), with rulings appealable before the Conseil d'État. Landmark actions include Société Générale (2017), BNP Paribas (2017) and La Banque Postale (2017), predominantly on AML/CFT grounds. This enforcement architecture and appeal route define the legal-risk exposure for supervised French payment entities.

A material risk-management development came on 18 March 2025, when the ACPR confirmed that financial penalties imposed by administrative authorities are uninsurable under French law on public-order grounds, warning that insurance clauses purporting to cover such penalties risk being declared null and void by French courts. This removes insurance as a backstop for ACPR fines — a direct consideration for French PSPs' governance and capital planning.

Outlook

The litigation posture is stable, anchored by the ACPR Sanctions Committee/Conseil d'État route and the uninsurability-of-fines position, alongside converging fraud-reimbursement case law tracked under W10.

Merchant Acquiring & Risk

The French acquirer market is dominated by domestic PSPs, and foreign acquirers often need a French PI or EMI to serve the French retail space efficiently. CB does not support commercial disputes or merchant-led fraud contestation, and PCI DSS plus 3D Secure are mandatory for e-commerce SCA. Wero operates a four-corner acquiring model built on SCT Inst with capped percentage fees. This market-access friction — the need for a French licence — and CB's dispute-design differences are operational realities for foreign acquirers, while Wero's four-corner model opens new A2A merchant acceptance.

Outlook

Merchant-acquiring operational detail is under-indexed this cycle, with coverage drawn substantially from vendor sources and the primary CB scheme-rulebook anchor not directly in register. The established trajectory holds: domestic-PSP dominance with an emerging A2A merchant-acceptance channel via Wero.

Product Innovation & Market Development

France is positioned at the front of the EU CBDC agenda. On 29 October 2025 the ECB Governing Council opened a new phase of the digital euro project to prepare technically for a potential launch; if the regulation is adopted by co-legislators in 2026, a pilot could begin as early as mid-2027 with a gradual launch from 2029, though no decision to issue has yet been taken. A retail digital euro would reshape French and EU payment economics, intermediary roles, and competition with private wallets and stablecoins.

On the wholesale track, in January 2026 governor Villeroy de Galhau stated the Banque de France was working on the 'Pontes project' to pilot a wholesale CBDC in 2026, framed as combating the 'privatisation' and 'Americanisation' of money. This builds on prior experiments — Project Venus with the Central Bank of Luxembourg, and DL3S Full-DLT Interoperability — and the 20 February 2025 Eurosystem decision to settle DLT transactions in central bank money via two tracks. Wholesale CBDC settlement for DLT market infrastructures is a leading French innovation track with sovereignty framing, relevant to tokenised-asset settlement operators.

Outlook

Two dated milestones anchor the outlook: the digital euro pilot pathway from mid-2027 (subject to 2026 co-legislator adoption) and the Banque de France Pontes wholesale-CBDC pilot scheduled for 2026.

Consumer Protection & APP Fraud

Where a transaction is recognised as unauthorised, the payer is usually entitled to immediate reimbursement, no later than the end of the first business day after dispute, subject to refusal only for user fraud or, in limited cases, gross negligence; the OSMP recommends strong authentication when accessing online banking from a new terminal, and ACPR Recommendation 2024-R-02 (2 July 2024) governs complaint-handling. These reimbursement obligations and the gross-negligence carve-out define PSP fraud-liability exposure for French consumers.

APP-fraud liability is shifting decisively onto PSPs. The incoming PSR extends the Verification of Payee regime to all credit transfers and, under Article 59, qualifies impersonation and spoofing fraud as reimbursable, reallocating fraud risk onto PSPs especially in social-engineering scenarios; political agreement was reached November 2025. French Cour de cassation 'intention to pay' case law shapes the assessment of disputed authenticated transactions. PSR Art. 59 plus convergent French case law materially expand PSP APP-fraud reimbursement liability.

Outlook

The trajectory is escalating: PSR Article 59 impersonation-fraud reimbursement and VoP extension to all credit transfers, expected in 2026, will further reallocate fraud risk onto French PSPs.

AML/CFT & Financial Crime

This module is sourced from the Sentinel feed; illicit-finance analysis is not re-performed here. Per Sentinel, the ACPR supervises banking-sector AML and the AMF the markets and crypto sector; suspicious transactions are reported to TRACFIN, France's FIU. The EU AMLA (Reg. (EU) 2024/1620, launched 1 June 2025) supervises high-risk financial-sector entities. AML/CFT firm penalties can reach EUR 100m or 10% of global annual turnover (individuals up to EUR 5m), with sanctions including licence suspension or cancellation. This supervisory architecture and the penalty ceilings frame compliance cost and licence-risk for French payment entities, with AMLA adding an EU-level layer.

Original illicit-finance, sanctions-evasion and stablecoin-misuse analysis is routed to the Financial Integrity Monitor as a cross-reference and is not a World Payments conclusion.

Outlook

The AML/CFT architecture is established; the principal forward variable is the bedding-in of the EU AMLA layer over the supervisory roles held by the ACPR, AMF and TRACFIN. Detailed illicit-finance horizon analysis sits with the Sentinel/FIM track.