title: France — Licensing, Authorisation & Market Access | World Payments Monitor canonical: https://payments.gi/jurisdictions/france/w1a/ publisher: Asymmetric Intelligence ### W1a Licensing, Authorisation & Market Access 1 gap Confirmed confirmed 2026-06-23 France operates under the post-Brexit-irrelevant EEA/PSD2 layer, supervised by ACPR (authorisation) and Banque de France (payments oversight). The EU PSD3/PSR package reached political agreement on 27 November 2025; formal adoption/OJ publication is expected H1-Q3 2026, with an 18-24 month transposition window for PSD3 and an 18-month PSR application delay thereafter, meaning France's national authorisation regime (Code Monétaire et Financier) will need amendment on that timeline. Open gap — wpm-int-1 No France-specific W1a MiCA/PSD3 commencement instrument located this cycle._no under-indexing note recorded_ Horizon · 2026-Q3 (± six months) PSD3/PSR Official Journal publication and national transposition_Adopted · Tier 3 source_ Horizon · 2026-Q2 (± six months) PSD3/PSR formal Official Journal publication_Adopted · Tier 3 source_ Horizon · 2026-Q2 (± six months) PSD3/PSR formal Official Journal publication_Adopted · Tier 3 source_ Horizon · 2026-Q3 (± six months) PSD3/PSR formal adoption and OJ publication_Adopted · Tier 1 source_ Horizon · 2026-Q2 (± six months) PSD3/PSR formal OJ publication_Adopted · Tier 3 source_ Horizon · 2026-Q4 (± six months) PSD3/PSR adoption and OJ publication expected_Adopted · Tier 3 source_ Standing sub-brief · as of 8 July 2026 386 words · last cycle 2026-09-21 #### 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. Periodic update · new data 2026-09-21 #### Licensing, Authorisation & Market Access Political agreement on the third Payment Services Directive (PSD3) and the accompanying Payment Services Regulation (PSR) was reached on 27 November 2025, with formal Official Journal publication expected in the first half or second quarter of 2026, a probable-confidence finding from law-firm commentary not yet corroborated against a primary EU Official Journal citation this cycle. The reform's central structural feature is a proposal to merge the payment institution and e-money institution licence categories into a single licence category, which would materially simplify the EU payment-licensing landscape by removing the current distinction that bank and non-bank payment providers must navigate separately. In anticipation of formal publication and the transposition timelines that will follow, the ACPR and Banque de France are expected to prioritise fraud-prevention readiness, IBAN-verification infrastructure and incident-reporting capability in early PSD3/PSR supervisory reviews, again a probable-confidence finding from the same commentary source. This carries the bank-PSP versus non-bank payment-institution distinction directly: the licence-category merger would apply across both bank-affiliated payment service providers and non-bank payment institutions and e-money institutions currently licensed separately. #### Outlook Formal Official Journal publication of PSD3/PSR, expected in the first half or second quarter of 2026, is the concrete milestone to watch, as it will trigger the transposition and application timelines that determine when the PI/EMI licence-category merger takes legal effect. A primary EU Official Journal citation for the political agreement itself remains an evidence gap this cycle. **3 earlier distinct update(s)** Periodic update · new data 2026-09-13 #### Licensing, Authorisation & Market Access The defining development for France's payments licensing environment this cycle is upstream and supranational: EU Parliament and Council negotiators reached political agreement on the PSD3/PSR package on 27 November 2025. Formal Official Journal publication is expected sometime in the H1-to-Q3 2026 window, a range that has not yet been reconciled across the sources reaching this cycle, and once published will trigger an 18-to-24-month PSD3 national-transposition period followed by an 18-month PSR application delay. France's Code Monétaire et Financier, the primary domestic instrument governing payment-institution and e-money-institution authorisation, will require amendment on whatever exact timeline finally crystallises from that publication date. Forward-looking supervisory expectation, rather than a confirmed rule at this stage, points to the ACPR and Banque de France prioritising fraud-prevention readiness, Verification of Payee infrastructure and incident-reporting capability in early PSD3-adjacent supervisory reviews. This is a probable-confidence signal drawn from secondary legal commentary rather than a published supervisory statement, and should be read as an indication of likely early-review focus areas rather than settled supervisory policy. The practical licensing implication for market entrants and existing payment institutions and e-money institutions operating in France is a multi-year forward horizon rather than an immediate compliance deadline: no PSD3/PSR-driven authorisation change applies to French firms yet, but the transposition clock, once the OJ publication date is fixed, will define the window in which national authorisation regimes must be brought into alignment with the new EU framework. The bank-PSP versus non-bank payment-institution/e-money-institution distinction remains structurally relevant here, since PSD3's transposition will apply across both categories under the existing Code Monétaire et Financier authorisation architecture, though no differential treatment between the two categories has been identified in this cycle's evidence. #### Outlook The immediate watch item is reconciliation of the PSD3/PSR OJ-publication date, currently uncertain between H1 and Q3 2026 across trackers. Once fixed, the transposition and application-delay clocks begin running in parallel, and the ACPR/Banque de France supervisory-priority signal, currently only a probable-confidence forward expectation, should be watched for confirmation as formal supervisory guidance emerges. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access PSD3 and the companion Payment Services Regulation reached political agreement between the European Parliament and Council on 27 November 2025, with formal Official Journal publication expected in H1 2026. This is the single most significant licensing and market-access development touching France this cycle, given the direct-application design of the PSR component: once entry into force occurs, the PSR applies without a domestic transposition step, while PSD3 itself carries an estimated 18-24 month transposition deadline. Within the package, Verification of Payee, presently confined to euro instant credit transfers under the amended SEPA/Instant Payments Regulation, is extended to cover all credit transfers regardless of currency or settlement speed. For payment service providers licensed in or passporting into France, this is a direct build requirement: payee-name-matching infrastructure that today only needs to cover instant euro transfers will need to be extended across the full transfer population. The market-access implication is structural rather than incremental. Extending Verification of Payee to all credit transfers changes the baseline fraud-prevention capability expected of any PSP operating in the French and broader EU market, effectively raising the compliance floor for market entry regardless of a firm's specific licence category. Both bank-PSPs and non-bank payment institutions and e-money institutions face the same extended Verification of Payee obligation under the PSR text as currently understood, since the requirement attaches to the payment service rather than to the type of licence held. #### Outlook The timing of formal Official Journal publication, expected in H1 2026, is the key variable that will fix the transposition and direct-application clocks for PSD3 and the PSR respectively. Firms should treat the 18-24 month PSD3 transposition window and the PSR's roughly 18-month direct-application period as provisional until the entry-into-force date is confirmed. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access The Council of the EU and European Parliament reached political agreement on the third Payment Services Directive (PSD3) and the Payment Services Regulation (PSR) on 27 November 2025, corroborated independently by both co-legislators' own press releases, giving this foundational development High confidence. The Council published final compromise texts on 23 April 2026, confirming the package's dual-instrument structure: PSD3 remains a directive requiring national implementation for authorisation, supervision and prudential matters, while the PSR is a directly applicable single rulebook that will apply uniformly across Member States without national transposition. For France, the package's most consequential structural feature is its collapse of the existing regulatory distinction between payment institutions (PIs) and electronic money institutions (EMIs) into a single, merged authorisation category. France's Code monétaire et financier currently organises payment-institution authorisation under Article L.521-1 with PI and EMI treated as related but legislatively distinct categories; while the Autorité de Contrôle Prudentiel et de Résolution already supervises both populations under one unified prudential authority, the underlying legislative frameworks for the two institution types are not fully integrated at the statutory level. Existing French EMI authorisations are expected to require reauthorisation as PIs under PSD3's merged category, with a transitional grandfathering window intended to smooth the transition, though the precise terms of that window have not yet been confirmed by a primary French regulatory source; this assessment currently rests on secondary law-firm commentary rather than a directly retrieved ACPR or Direction Générale du Trésor statement, and is held at Assessed rather than High confidence. A second material development within this module is the PSR's extension of verification-of-payee obligations. The regulation extends the name/IBAN verification-of-payee mechanism to all credit transfers, building on the existing Instant Payments Regulation mandate that already applies specifically to euro instant transfers, and it reallocates liability for authorised-push-payment fraud and spoofing scenarios onto payment service providers rather than leaving it with the paying customer. For French PSPs, this is a generalisation of an obligation already familiar from the instant-transfer context rather than an entirely novel compliance build, but the liability reallocation itself raises the practical stakes of implementation. The PSD3/PSR agreement and its French implementation implications apply across both bank and non-bank payment-service-provider populations: the PSR's verification-of-payee and fraud-liability provisions bind banks and non-bank PSPs alike, whereas the PI/EMI merger specifically reshapes the non-bank licensing tier, since banks in France operate under separate credit-institution authorisation and are not directly subject to the PI/EMI merger's reauthorisation mechanics. This bifurcation matters for market-access analysis: incumbent bank-affiliated payment processors face comparatively less licensing disruption than the standalone non-bank PI/EMI population that must navigate reauthorisation. #### Outlook The PSD3/PSR package is expected to move from final compromise text to Official Journal publication around the third quarter of 2026, which will start the transition-period clock before full application; the precise Official Journal date has not been confirmed by a primary source. France's own PI/EMI licensing-framework restructuring is expected to follow through the fourth quarter of 2026 and into 2027, with CMF Article L.521-1 requiring legislative amendment to accommodate the merged PI category. The transitional grandfathering terms for existing French EMI authorisations are the single most consequential unresolved detail for market participants and are the primary item to watch in the coming cycle. **Sources and findings (5)** 1. T1 [https://acpr.banque-france.fr/en/authorisation/banking-industry-procedures/licensing-authorisation-and-registration/electronic-money-institution](https://acpr.banque-france.fr/en/authorisation/banking-industry-procedures/licensing-authorisation-and-registration/electronic-money-institution) retrieved 2026-06-23 2. T1 [https://acpr.banque-france.fr/en/authorisation/banking-industry-procedures/licensing-authorisation-and-registration/electronic-money-institution](https://acpr.banque-france.fr/en/authorisation/banking-industry-procedures/licensing-authorisation-and-registration/electronic-money-institution) retrieved 2026-06-23 3. T1 [https://www.banque-france.fr/en/financial-stability/financial-stability-mandate/oversight-financial-institutions](https://www.banque-france.fr/en/financial-stability/financial-stability-mandate/oversight-financial-institutions) retrieved 2026-06-23 4. T3 [https://www.treezor.com/insights/knowledge-center/becoming-a-payment-institution-in-france-the-3-main-steps/](https://www.treezor.com/insights/knowledge-center/becoming-a-payment-institution-in-france-the-3-main-steps/) retrieved 2026-06-23 5. T1 [https://acpr.banque-france.fr/system/files/2025-01/20220315_new_payment_stakeholders_overview.pdf](https://acpr.banque-france.fr/system/files/2025-01/20220315_new_payment_stakeholders_overview.pdf) retrieved 2026-06-23