France’s tax office can make a crypto platform sell a customer’s coins to pay off a tax debt, without going to a judge. The power comes from article 90 of loi n° 2026-534 du 25 juin 2026 on social and tax fraud, published in the Journal officiel on 26 June 2026 and in force since then. It drew new attention on 27 October, when Journal du Coin pointed out that the decree setting its deadlines has still not appeared, and that coins kept in a self-custody wallet are out of its reach.
This crypto seizure power is not new law, and nothing was voted this week. Investors are only now noticing that a four-month-old text extends to crypto the tool the Treasury already uses on bank accounts and salaries.
What paragraph 2 bis of article L. 262 lets the tax office do
The tool is the saisie administrative à tiers détenteur, or SATD, an administrative seizure from a third party. The tax office’s own explainer describes it as a way to ask someone who holds your money, such as a bank, an employer or a pension fund, to pay your unpaid tax in your place. A bank served with an SATD has 30 days to transfer the funds. No court decision is needed. It rests on article L. 262 of the Livre des procédures fiscales (LPF).
Article 90 inserts a new paragraph 2 bis into that article. When the seizure targets digital assets held by a digital-asset service provider (a PSAN in French law, a crypto-asset service provider under the EU’s MiCA rules), it applies to the whole portfolio held on the day of the seizure, up to the amount owed. The taxpayer does not pick which coins go first, Journal du Coin notes: bitcoin, ether and a forgotten memecoin all count.
The power is not limited to fraud cases, despite the title of the law. Thomas Louvel of CMS wrote on 2 September 2026 that it can be used to recover any debt owed to the Treasury.
Notaries Clément Colombel and Joseph Depierre of Michelez Notaires put it in one line on 22 July 2026: “Le crypto-actif n’est plus seulement imposable et déclarable, blockchain that runs exactly as written when it is called, holding and moving funds according to its code, without an intermediary able to change the outcome.">smart contract holding reserves of two or more tokens, supplied by users, that a decentralized exchange uses to execute trades automatically at a price set by a formula.">pool diverge, compared with simply holding the same tokens in a wallet. It becomes permanent when the provider withdraws.">il devient saisissable.” Crypto, in other words, is no longer only something to tax and report. It can now be seized.
How the crypto seizure and forced sale work, step by step
A platform cannot hand bitcoin to the Treasury, so the text sets out a sequence. As described by Michelez Notaires and Journal du Coin:
- The tax office notifies the SATD to the platform holding the assets, for an amount up to the tax owed.
- The taxpayer has a window to sell the assets themselves. The length of that window is set by decree.
- If the taxpayer does not sell in time, the platform sells the assets if it is authorised to do so, or entrusts the sale to a provider that is.
- The proceeds go to the Treasury in euros or in a foreign currency, within a second deadline also set by decree.
The sale carries immediate attribution of the proceeds to the seizing creditor, up to the amount seized, with effect from the date the seizure was notified. In plain terms, the money from a later sale is treated as the Treasury’s from the day the platform received the notice.
Why French tax collectors could not touch crypto before
The SATD was built for money. The explanatory statement of amendment CF91, where the measure first appeared, says crypto-assets “ne sont assimilables ni à de la monnaie ayant cours légal, ni à des créances de sommes d’argent”: they are neither legal tender nor a money claim, so the procedure could not reach them. Until June the only route to a forced sale went through a commissaire de justice, the French court enforcement officer, with the slower steps that implies.
CF91, dated 5 December 2025 and tabled in the National Assembly’s finance committee by deputy Baumel and eight colleagues, was adopted there. Its reasoning comes down to one line: “Leur vente est donc un préalable nécessaire”, meaning the assets have to be sold before the debt can be recovered. Journal du Coin reports that the version adopted on 10 December in the committee leading on the bill was carried by deputy Daniel Labaronne, the finance committee’s rapporteur. The amendment cites the risk of crypto being used to hide taxable wealth but gives no figure on the scale of that fraud.
The bill was adopted by the Assemblée nationale on 5 May 2026 and by the Sénat on 11 May 2026, according to CMS Francis Lefebvre, which said on 10 June that the article 90 measures apply from the day the law is published. CMS added that none of the tax measures had been referred to the Conseil constitutionnel. The law was promulgated on 25 June and published the next day.
Platform fees capped at the level banks already face
Exchanges will be allowed to charge for handling a seizure, within limits. Under the law’s text on Légifrance, a new point 6 caps the SATD fees that digital-asset service providers may charge at the level already set in point 5 of article L. 262 for banks. The tax office’s help page puts that bank cap at 10% of the amount owed to the tax administration, with an overall ceiling of 100 euros including tax under a decree of 10 December 2018.
Journal du Coin reads this as the same 10% limit for platforms, within a ceiling fixed by decree. The 100-euro ceiling comes from a decree written for banks, and no text so far says whether it covers crypto platforms or whether a separate amount will follow.
The decree setting the deadlines is still missing
Both deadlines in paragraph 2 bis, the taxpayer’s window to sell and the platform’s time to pay the Treasury, are left to a decree. CMS wrote on 2 September that the first deadline “doit encore être fixé par décret” (must still be set by decree). On 27 October, four months after the law took effect, Journal du Coin reported that the decree had still not appeared in the Journal officiel.
For bank accounts the timetable is known: 30 days for the bank to pay. For crypto, the clock has not been set.
Self-custody wallets and foreign platforms stay out of reach, for now
The new paragraph only covers assets “conservés par un prestataire”, held by a provider. Coins in a wallet whose private keys the owner controls, such as a hardware wallet, are not caught by this procedure, CMS and Journal du Coin both say; they remain subject to the ordinary enforcement routes through the courts. Readers who want to understand the difference between an exchange account and a wallet they control can read how a centralised exchange holds customer crypto.
Platforms based outside France raise a question no source answers. Stéphanie Némarq-Attias, a lawyer at the firm Qomit, asked through Journal du Coin how the rule applies to providers established abroad and how it fits with international assistance in tax recovery. An SATD is a notice served on a third party; how the French tax office would serve and enforce it on an exchange with no French entity has not been explained.
There is also a possible tax bill on top of the debt. Journal du Coin notes that converting crypto into euros is in principle a taxable event under article 150 VH bis of the French tax code, so a forced sale could produce a capital gain to declare the following year. That is the outlet’s reading of the general rule, not an official position on forced sales.
The same law tightens crypto reporting
Article 90 also extends to undeclared foreign crypto accounts the special ten-year period in which the tax office can reassess registration duties and the real estate wealth tax (IFI), CMS and Michelez Notaires say. The duty to declare crypto accounts held abroad now also covers unique non-fungible tokens, so they will appear in returns filed in 2027. CMS lists fines of “up to 1,500 euros” per undeclared wallet or NFT; Michelez Notaires set out the detail, 750 euros per undeclared NFT, raised to 1,500 euros when its market value passes 50,000 euros during the year. Our guide to crypto taxes in France covers the flat tax and the forms.
Reporting is moving the same way. Under the EU’s DAC8 rules, providers collect and send user transaction data from 1 January 2026, and France is now working on the OECD framework that reaches platforms outside the EU, which we covered in our report on CARF in the French Senate. The tax office will see more of where crypto sits; for coins held by a provider, it can now also collect.
How an IRS levy on crypto compares
The US tax authority already does something similar, by a different route. The Internal Revenue Manual chapter on levies in special cases, IRM 5.11.6.21.1 (revised on 14 March 2024), says a taxpayer’s interest in crypto held by a virtual asset service provider (VASP), such as a hosted wallet provider or an exchange, is subject to collection. A paper levy served on a US-based VASP “should be honored” and the provider should convert the assets into dollars at the current price.
Revenue officers use Form 668-A, give the VASP a reasonable period to convert, and must first check that the provider is located in the United States. A VASP that qualifies as a bank holds the funds for 21 calendar days before paying. Before any levy, IRC 6330 gives the taxpayer notice and a chance to request a hearing.
Both procedures turn crypto held by a provider into cash for the Treasury, and both stop at the border: the IRS tells its officers to check the provider is in the US before levying. They differ on who sells. France gives the taxpayer a window to sell first and caps what platforms can charge, while the IRS manual asks the provider to liquidate and mail a check to the United States Treasury. US readers can compare with our guide to how the IRS taxes crypto.
What to watch next
The decree is the first thing to look for in the Journal officiel, since it decides how long a taxpayer has to sell and how fast the money must reach the Treasury. No figures on seizures made under the new paragraph have been published.
The government also wants to go further. Article 30 of the 2027 budget bill would extend forced sales to securities accounts, Journal du Coin and Selectra report: if the taxpayer does not sell, the bank or broker holding the account would. The bill has not been voted.