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The five-part test for a French crypto-account declaration
Do not start with the word “wallet”. French reporting turns on the taxpayer’s residence, the foreign location of an account relationship, the provider’s custody activity, what happened during the tax year and who controlled the account. Work through all five questions before deciding that no form is needed.
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| Question | If the answer is yes | What to document |
|---|---|---|
| Were you domiciled in France for tax purposes? | The foreign-account rules can apply to you as an individual, and to certain non-commercial entities. | Your facts under Article 4 B of the General Tax Code; do not rely on citizenship alone. |
| Was the account or service abroad? | Continue the test for a foreign digital-asset account. | The provider’s legal name, address, country, website and contractual account details. |
| Did the provider habitually receive digital assets in deposit? | The relationship matches the description used in the 2026 income-tax brochure. | Terms of service, custody wording and the provider’s identity. |
| Was it opened, held, used or closed during 2025? | It belongs in the 2026 filing-season review even if it was later closed. | Opening, closing, transaction and access records. |
| Were you a holder, joint holder, economic beneficiary, beneficial owner or proxy holder? | Your role may create a reporting duty even when someone else operated the account. | Ownership, mandate and control documents. |
If any answer is uncertain, preserve the facts rather than guessing. The form asks for enough detail to identify the provider and account, and an adviser can assess a borderline custody or control arrangement.
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The starting point is residence, not nationality. The official foreign-account guidance refers to individuals domiciled in France under Article 4 B of the General Tax Code. A French passport, a French bank account or occasional stays in France does not by itself settle that question.
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Residence facts to review
- Where your household and principal home were located during the year.
- Where you carried out your main professional activity, subject to the statutory exceptions.
- Where the centre of your economic interests was located.
- Whether a tax treaty or a documented move changed your residence during 2025.
Keep the residence analysis separate from the wallet analysis. A person can hold a foreign account without being within the French reporting rule if they were not French tax-domiciled for the relevant period; conversely, a French resident can be in scope even when the provider has no French office.
Who can be covered besides the named customer?
The administrative guidance discusses holders and proxy holders and also refers to joint holders, economic beneficiaries and beneficial owners. That means you should examine accounts operated for a family member, company or client, not only accounts registered in your own name. The precise obligation depends on the legal and factual role, so retain mandates and ownership records.
2. Identify a foreign digital-asset account, not merely an asset
The rule concerns an account relationship. The 2026 income-tax brochure describes covered digital-asset accounts as accounts held with a person or entity that habitually receives digital assets in deposit. The provider’s role is therefore material: ownership of a token or a wallet address, by itself, is not the test.
Information that indicates an account relationship
- A service provider creates or maintains an account in your name or for your benefit.
- The provider receives, safeguards or controls digital assets on an ongoing basis.
- You can log in to an account, request transfers or use a custody balance maintained by that provider.
- The provider supplies legal identification and account-opening or closing information that can be reported.
Record the provider’s legal name, postal address, website, account designation or number, account type and use, and opening or closing date. These are the kinds of details the 3916-3916 bis process requests. A trading interface may still represent a custodial account when the service holds the assets, so look at the contractual and operational custody arrangement rather than the screen label.
What “abroad” means for this check
Assess where the provider or account is established under the official form’s identification requirements. Do not infer location from a brand name, a language setting or the location of a mobile app. Use the legal entity and address shown in the contract, account notices or provider register, and keep a copy dated during the relevant year.
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3. Check activity during the filing year
For the 2026 filing season, the brochure addresses accounts held during 2025. An account is relevant if it was opened, held, used or closed abroad at any point in that year. A zero balance or a later closure does not erase an account that otherwise met the test while it was active.
Build a 2025 account timeline
- List every foreign provider used between 1 January and 31 December 2025.
- For each provider, note the opening date, any period of use, and the closing date if applicable.
- Mark whether the provider held assets in deposit and whether you could initiate transfers or trades.
- Save statements or account-history exports that show the period of activity.
The general official guidance says the declaration accompanies the annual income or results return. Use the filing year’s current instructions rather than copying fields from an earlier form: online screens and form editions can change.
4. Determine your legal role on the account
Reporting is not limited to the person who clicked “open account”. Review whether you were the account holder, a joint holder, an economic beneficiary, a beneficial owner or a proxy holder. A mandate that lets you operate another person’s account can require a different analysis from an account you own, but it should not be ignored.
Questions for shared or managed accounts
- Whose name appears on the provider’s customer record?
- Who supplied identification and who could withdraw or transfer assets?
- Who was entitled to the economic benefit of the assets?
- Did a power of attorney or management agreement give you proxy authority?
- Was the account held jointly, and does the provider identify each joint holder?
Describe the role accurately in your records and seek advice if ownership and control diverge. The official materials use several categories because legal entitlement and practical access are not always the same.
5. File the correct form with the 2026 return
For applicable accounts, the 2026 income-tax brochure directs taxpayers to box 8UU and form 3916-3916 bis. The French tax authority says the deadline is the same as the annual income or results return.
Online filing
- Start the 2026 online income or results return for the year 2025.
- At the foreign-account section, select the declaration for foreign digital-asset accounts and confirm box 8UU when the service presents it.
- Complete a 3916-3916 bis record for each qualifying account or provider relationship, following the fields shown in that year’s interface.
- Enter the provider’s name, address and, where requested, website; identify the account designation, type and use; and provide opening and closing dates.
- Review declarant, holder and proxy information, then submit the form with the main return and retain the electronic acknowledgement.
Paper or signed submission
The form instructions also describe signed filing and paper submission. Use the edition applicable to the filing year, complete every required identification field and send it through the route specified by the tax authority. Do not substitute an old PDF when the current instructions provide a different field or filing channel.
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One provider or several accounts
Make the declaration traceable to each qualifying account. If a provider gave you separate accounts with different opening, closing or use details, follow the form’s instructions on whether they require separate entries. Keep a reconciliation showing how your internal list maps to the submitted forms.
6. Gather the information before opening the form
| Data item | Useful evidence | Why it matters |
|---|---|---|
| Provider legal identity | Terms, account statement, regulatory or company details | Identifies the foreign person or entity receiving assets in deposit. |
| Address and website | Contract and provider correspondence | The brochure says these details may be requested. |
| Account designation, type and use | Dashboard export, onboarding record, product description | Explains what relationship you are reporting. |
| Opening and closing dates | Welcome email, closure confirmation, statement history | Shows whether the account existed during 2025. |
| Holder or proxy status | Mandate, joint-holder record, beneficial-ownership documents | Supports the person’s role in the declaration. |
| Residence and filing records | Tax notices and prior returns | Supports the French-residence analysis and preserves a filing trail. |
Download records before closing an account or losing access to a provider. Store the submitted form and acknowledgement with the underlying evidence for the period required by your French tax-record obligations.
Penalties stated for the 2026 filing season
The Direction générale des Finances publiques’ 2026 income-tax brochure states the following amounts for omissions or inaccuracies concerning the covered reporting year. They are brochure figures tied to that edition; verify the rules for any later filing year.
| Situation described in the brochure | Stated amount | Limit or condition |
|---|---|---|
| Undeclared digital-asset account | €750 per account | Combined penalty capped at €10,000 per declaration. |
| Omission or inaccuracy | €125 per omission or inaccuracy | Combined penalty capped at €10,000 per declaration. |
| Relevant foreign-held digital-asset accounts worth more than €50,000 at any time during the year | €1,500 per undeclared account; €250 per omission or inaccuracy | The brochure states the increased amounts for this value condition, subject to the €10,000 per-declaration cap. |
The brochure’s French wording is: «Toute omission ou inexactitude dans votre déclaration vous expose à une amende de 750€ par compte non déclaré ou de 125€ par omission ou inexactitude, dans la limite de 10000€ par déclaration.» Treat the quoted figures as time-sensitive administrative guidance, not a permanent rate card.
Do not confuse account reporting with crypto-disposal taxation
Submitting 3916-3916 bis reports the qualifying foreign account. It does not calculate the tax on selling, exchanging or otherwise disposing of digital assets. Those are separate questions on the annual return.
Disposal reporting
For individuals, the tax authority describes a separate process that can include form 2086 to report the resulting gain or loss where applicable. Gather transaction dates, proceeds, acquisition costs and the calculation required by the current instructions. A disposal calculation cannot replace the foreign-account form, and filing the account form does not replace a required gain or loss declaration.
The €305 threshold
Current online guidance states a €305 annual gross-disposal-price threshold for exemption from tax in specified individual digital-asset disposal cases. That threshold concerns disposal taxation. It is not a threshold for deciding whether a qualifying foreign account must be reported. A person below €305 in gross disposals can still have a 3916-3916 bis obligation.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Self-custody wallets and decentralised protocols: where the answer is not settled
A self-custody wallet controlled directly by you, with no account at a foreign custodian or service provider, is not expressly classified in the official materials reviewed. The same uncertainty can arise when a decentralised protocol has no clearly identifiable person or entity that habitually receives assets in deposit.
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Facts that point toward a custodial account
- A company or other identifiable provider holds the private keys or pooled assets.
- The provider maintains a customer balance or account record.
- You can request a withdrawal from the provider rather than signing a blockchain transaction from your own key.
- The service’s terms describe custody, deposit, safeguarding or equivalent control.
Facts that create an unresolved boundary
- You hold the private keys and interact directly with a blockchain address.
- No foreign entity maintains an account, balance or customer record for you.
- A protocol is automated and decentralised, with no obvious account provider or depositary.
- Several interfaces route transactions but do not themselves custody assets.
Do not state categorically that every wallet address is reportable or that self-custody is automatically exempt. Document the architecture, the entities involved and your control of keys, then ask the tax authority or a qualified French adviser for a fact-specific view.
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How to compare two wallets or services
When two arrangements look similar in an app, compare the legal facts rather than the user interface.
| Comparison axis | Questions to ask |
|---|---|
| Residence | Were you French tax-domiciled during the relevant year? |
| Foreign location | Where is the provider or account established, and what legal entity is named? |
| Custody or deposit | Does an identifiable person or entity habitually receive or hold assets in deposit? |
| Timing | Was the arrangement opened, held, used or closed during 2025? |
| Role | Are you a holder, joint holder, economic beneficiary, beneficial owner or proxy holder? |
| Decentralisation | If there is no clear provider, does the official guidance resolve the specific structure? If not, obtain individual advice. |
CARF and DAC8 information transfers are a separate framework
The tax authority’s CARF/DAC8 information-transfer page, modified 20 July 2026, lists CGI Articles 1649 AC bis through sexies and Decree No. 2025-1276 of 19 December 2025 on crypto-asset service-provider reporting and due diligence. That framework concerns information exchanged or transmitted by providers.
The page does not establish that those provisions change the personal 3916-bis applicability test described in the income-tax brochure. A provider’s reporting to authorities therefore should not be treated as a substitute for your own declaration, nor as proof that every self-custody arrangement is covered.
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Ask for a written, fact-specific assessment when the provider’s legal location is unclear, custody is split between entities, you acted as a proxy or beneficial owner, you moved residence during 2025, or a decentralised protocol does not fit the account description. Bring the provider contracts, custody terms, account timeline, role documentation and a diagram showing who controlled assets and keys.
If you discover a possible omission after filing, do not silently duplicate forms or alter records. Contact the tax authority or your adviser promptly, explain the account timeline and follow the correction procedure applicable to that filing year.
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