Update, 28 October 2026, 12:30 UTC: The French Senate approved the CARF bill at first reading on Tuesday 27 October, without changing it, according to the text adopted and signed by Senate President Gérard Larcher. It was sent the same day to the National Assembly, where it is registered as bill n° 3421 and assigned to the foreign affairs committee. No date had been set there as of 28 October, and none of the Senate pages we checked gives a vote count.
The French Senate on Tuesday 27 October approved the bill that lets France approve the OECD agreement on the Crypto-Asset Reporting Framework (CARF), the system under which tax authorities blockchain, where users swap tokens directly from their own wallets without handing custody of their funds to a company.">swap data on their residents’ crypto accounts held abroad. The text, projet de loi n° 921, was filed by Foreign Minister Jean-Noël Barrot on 27 July 2026, and the Senate’s finance committee had adopted it without changes on 21 October, according to the Senate’s legislative file and the committee’s summary.
It passed at first reading, under the accelerated procedure. The text adopted by the Senate (n° 21 of the 2026-2027 session) keeps the two articles exactly as the government wrote them, with no amendment. Nobody expected otherwise. A treaty approval bill is voted as a whole: senators can approve or reject the two agreements, not rewrite them, and the committee had raised no objection. What matters for crypto holders is what the agreements switch on.
Take a French resident with an account on an exchange based outside the European Union. From 2027, the French tax administration (DGFiP) is set to start receiving, automatically and every year, the identity, tax residence and transaction totals reported by foreign crypto platforms in partner countries. Until now, those accounts surfaced mostly when an inspector went looking.
Two OECD agreements, one bill: what the Senate approved
The bill has two articles. The first approves the multilateral competent authority agreement on automatic exchange of information under CARF (“AMAC CDC” in French). The second approves an addendum to the 2014 agreement that already organises the exchange of bank account data under the OECD’s Common Reporting Standard (CRS). Both were signed in Asunción, Paraguay, on 26 November 2024, when France signed alongside 48 other states and territories, according to the government’s explanatory memorandum.
The number of signatories of the crypto agreement has since reached 56, according to the Senate committee’s summary, which cites the OECD. The government’s impact study gives the same count, based on the OECD’s list of signatories as of 3 March 2026. It names the 49 that signed on the first day in Asunción, the United Kingdom, Switzerland, Singapore, Japan, Canada and Brazil among them. The United States is not one of them. The committee adds that other jurisdictions have committed to apply CARF without signing yet, and that coverage is still incomplete.
Approval by Parliament is required by Article 53 of the French Constitution for agreements of this kind, the impact study notes. The government asked for the accelerated procedure on the day it filed the text, so a single reading in each chamber can be enough. The Senate went first and approved the text on 27 October. The National Assembly is next: the bill was registered there the same day as n° 3421 and sent to the foreign affairs committee, with no date set for committee or floor debate as of 28 October, according to the Assembly’s legislative file.
A short sitting: support from left to right, no amendment
The debate on 27 October held no surprise, according to the Senate’s summary record of the sitting. Eléonore Caroit, the minister delegate for Francophonie, international partnerships and French nationals abroad, presented the bill. Approval of the agreements “permettra l’échange automatique des informations collectées avec nos partenaires” (will allow the automatic exchange of the information collected with our partners), she said. Rapporteur Emmanuel Capus, for the finance committee, recommended adoption and restated the timetable: “Les premiers échanges sont prévus à partir de 2027” (the first exchanges are planned from 2027).
Speakers for seven groups announced a vote in favour, from the CRCE-K on the left to Les Républicains, the Union centriste and the RDPI, and Grégory Blanc said he would vote for it too. Nathalie Goulet (Union centriste) backed the text with reservations on data security and on how many countries the system covers. The Socialist speaker, Alexandre Ouizille, called the bill welcome but raised criticisms, without stating how his group would vote.
The result is known; the margin is not. Neither the legislative file, nor the adopted text, nor the sitting summary gives a vote count or the exact time of the vote, and Journal du Coin, which reported the adoption on 28 October, gives none either.
Approval does not switch the exchanges on by itself. Signing the agreement does not make them operational, Journal du Coin noted, citing Capus’s report: each country must first confirm to each partner that it is ready. France will also require its partners to respect the EU’s data protection rules (GDPR), according to the same outlet. It counts 77 jurisdictions committed to CARF as of 14 September 2026: 46 exchanging from 2027, France among them, 27 from 2028, Switzerland and Singapore included, and four from 2029, including the United States, which has not signed the agreement.
What CARF is, for readers outside France
CARF is the crypto counterpart of the CRS, the standard that since 2017 has made banks and other financial institutions in more than 122 states and territories report foreign customers’ accounts to their own tax office, which then forwards the data to the customer’s country of residence. Crypto slipped through that net because coins can be held and moved without a bank. At the G20’s request, the OECD drew up CARF and adopted it in 2023.
The framework puts the reporting duty on crypto-asset service providers, such as exchanges and brokers. They must identify their users and their tax residence, then report the nature, number and value of three kinds of operations: exchanges between crypto and fiat money, exchanges between crypto-assets, and transfers of crypto-assets. Each provider sends that file to its local tax authority, which passes it on to the users’ home countries within nine months after the end of the calendar year, through the OECD’s encrypted common transmission system, according to the explanatory memorandum.
The United Kingdom shows how the timing works on the ground. UK crypto service providers must file their first report, covering 1 January to 31 December 2026, between 1 January and 31 May 2027, then by 31 May every year for the previous calendar year, according to HMRC’s reporting guidance. They collect details on all users but report those who are tax resident in the UK or in another country signed up to CARF. HMRC may charge up to £300 per user for a missing, late or inaccurate report.
CARF goes beyond the EU’s DAC8, which France already applies
France did not wait for this treaty to impose the reporting. The EU folded both CARF and the revised CRS into its own law with the DAC8 directive of 17 October 2023, and France wrote it into the 2025 finance law (article 54 of law n° 2025-127 of 14 February 2025, which created articles 1649 AC bis to 1649 AC sexies of the tax code). Two decrees of 19 December 2025 (n° 2025-1276 for crypto, n° 2025-1277 for the revised CRS) set out the details. Platforms have been collecting data on transactions since 1 January 2026, and the first declarations are due in 2027, the Senate committee notes.
DAC8, however, only organises exchanges among the 27 EU tax administrations, with a first exchange due by 30 September 2027 (see our DAC8 first exchange explainer). The OECD agreement is the legal basis France needs to receive, and send, the same kind of data with countries outside the Union. According to the committee, it will let the French administration receive information on operations carried out by French tax residents with providers established abroad.
In practice, and this is our reading of the texts, a French resident using a platform established in another EU country is already covered by DAC8. The CARF agreement changes the picture for accounts on platforms located outside the EU, in jurisdictions that have joined the framework. A UK-based exchange is the obvious case, since the UK has signed and starts reporting in 2027.
The exchange calendar is staggered. France’s first exchanges are due in 2027 on data collected in 2026, according to the impact study, while jurisdictions facing particular difficulties with that timetable may start in 2028. The Senate summary only says that some states chose a later deadline, without listing them.
The bank data precedent: 11.6 million foreign accounts reported to France
The committee leaned on the bank account system to show what automatic exchange can deliver. In 2025, for the year 2024, France received data from 109 partner jurisdictions on 11.6 million financial accounts with a combined balance of 456 billion euros, according to figures the tax legislation directorate gave rapporteur Emmanuel Capus. The first collection, covering 2016, had ten times fewer accounts.
| CRS data received by France | Data year 2016 | Data year 2024 |
|---|---|---|
| Financial accounts reported | 1.16 million | 11.6 million |
| Combined balance | 80 billion euros | 456 billion euros |
| Partner jurisdictions | n/a | 109 |
Worldwide, CRS exchanges covered 171 million accounts worth 13,000 billion euros in 2024, according to the impact study. The addendum the Senate has just approved updates that system to the 2023 revision of the CRS, which brought in certain e-money products, central bank digital currencies and indirect crypto exposure through derivatives and funds. It adds new fields to each report: whether the holder gave a valid self-certification of tax residence, the type of account, whether it is new or pre-existing and how many people hold it jointly. That addendum has 72 signatories, the impact study says.
For crypto, nobody is promising a figure. The volume of data the administration will receive from 2027 “demeure toutefois difficile à évaluer à ce stade” (remains hard to assess at this stage), the committee wrote, for lack of hindsight on a first reporting campaign. The impact study puts the number of crypto holders in France at 1.5 million to 5 million people, or 3% to 9% of adults.
What the French tax office expects to catch
The committee lists the practices automatic exchange should expose: undeclared capital gains, the use of foreign exchanges and transfers of funds to external wallets. It also notes that failure to declare digital-asset accounts held abroad is frequently found by tax auditors today, but mainly during one-off investigations. Matching the incoming files against tax returns should make detection systematic, according to the committee’s summary.
None of this creates a new tax. The treaty moves data; the rules on how crypto gains are taxed in France stay where they are. The tax debate is happening elsewhere, in the 2027 budget, where MPs voted at first reading to tax swaps into dollar and euro stablecoins (our report on the stablecoin swap tax vote).
Form 3916-bis: the obligation that CARF data will be checked against
The declaration that CARF files will be compared with already exists. Every individual domiciled in France must declare each year the digital-asset accounts on foreign platforms that were “ouverts, détenus, utilisés ou clos” (opened, held, used or closed) during the year on form 3916-bis, with one form per account, according to Service-Public. The forms go in with the annual income tax return and share its deadline; online filers also tick the matching box in the return.
The penalties are set out on the government’s Service-Public page on foreign accounts, checked on 9 July 2026:
- a fixed fine of 750 euros per undeclared account;
- 1,500 euros per undeclared account when its value exceeded 50,000 euros at some point in the year concerned;
- an 80% surcharge on any tax reassessment that results from an undeclared crypto wallet held abroad.
Those rules apply today, with or without CARF. What changes from 2027 is the likelihood that the tax office already holds a foreign platform’s report on an account that the holder left off the form. Our guide to crypto taxes in France explains how form 3916-bis fits with the rest of the return.
What happens after the Senate vote
It is now up to the National Assembly, which registered the bill on 27 October as n° 3421; no date was on the calendar as of 28 October. Once the deputies approve it, the law still has to be promulgated and published in the Journal officiel, and no timetable has been given for those steps. Once Parliament has approved both agreements and France has sent its notifications to the OECD secretariat, exchanges can begin from the year stated in those notifications, according to the impact study. For France, that year is 2027, on data collected since January 2026.
For holders outside France, the Senate vote is one more step in a rollout that runs on parallel tracks: national reporting rules, such as the UK’s or Germany’s self-certification deadline for platforms, and treaty approvals like this one, which decide who receives the data. For French holders, data from EU platforms is due to reach the DGFiP by 30 September 2027 under DAC8. Data from non-EU partners such as the UK follows once both sides have notified the OECD, from 2027 on France’s commitment.