Definition
The PSAN (Prestataire de Services sur Actifs Numériques, France's digital-asset service provider status) is the French regime for crypto players, created by the PACTE law (2019): exchanges, custodial wallets, brokers, advisers.
The CASP (Crypto-Asset Service Provider) is its unified European equivalent, created by MiCA (June 2023, applicable to CASPs since December 2024). During a transition period (2024 → end of 2026), the two regimes coexist; in the end, the CASP replaces the PSAN.
The services covered
MiCA (and the PSAN before it) lists 10 CASP services: custody, order execution, placement, reception and transmission of orders, advice, portfolio management, exchange (crypto for fiat or crypto), operation of a trading platform, transfer, and exchange of funds. Authorisation is requested service by service.
PSAN: registration vs authorisation
In France, the PSAN comes in two tiers:
- Mandatory registration with the AMF (with the ACPR's binding opinion) for custody, buying/selling against fiat, crypto/crypto exchange and platform operation — with AML/CFT and good-standing checks. ~100 players registered by the end of 2024.
- Optional enhanced authorisation (DDADUE law, 2023), with a minimum capital and demanding governance — obtained by very few players (Coinhouse, Stackinsat).
With MiCA, PSAN registration is being gradually repealed: every PSAN will have to switch to CASP by June 2026.
The single CASP authorisation
MiCA's major contribution is the European passport: a CASP authorised in one member state can operate across all 30 EEA countries with no new authorisation. The authorisation is granted by the national authority (AMF/ACPR in France, BaFin, CySEC, MFSA, AFM…). MiCA imposes a minimum capital (€50k, €125k or €150k depending on the services), robust governance, segregation of client assets, pre-contractual disclosure for issuers, and a specific regime for stablecoins (ARTs and EMTs, with 1:1 backing and ECB reporting).
What PSAN / CASP does not cover
- Pure DeFi: decentralised protocols with no identifiable legal entity, outside MiCA's scope (a MiCA 2 is under study for 2026–2028).
- Non-fungible NFTs: excluded, unless issued in an interchangeable series.
- Holding and exchange by individuals: remain free; only providers are regulated.
- Security tokens: a tokenised share or bond falls under MiFID II, not MiCA.
Migration timeline
- 2019 — creation of the PSAN (PACTE law).
- June 2023 — adoption of MiCA.
- 30 June 2024 — stablecoin rules (ARTs/EMTs).
- 30 December 2024 — CASP rules (services).
- July 2026 — end of the transition period for existing PSANs.
Within the PSD2 ecosystem
PSAN / CASP is a regime parallel to PSD2: it creates no XS2A API obligation, but inherits PSPs' AML/CFT obligations (KYC, sanctions, monitoring). The Travel Rule (transmitting the sender/beneficiary identity for any crypto transfer over €1,000) creates a parallel with the SCA requirements of traditional payments.
Real-world examples
- French PSANs: Coinhouse (the first to be authorised), Stackinsat, Trakx, Bitstack, Paymium, Deblock — all transitioning to CASP.
- European CASPs: Binance France (applying), Coinbase Europe (Ireland), Kraken (Ireland), Bitpanda (Austria), Crypto.com (Malta).
- Choice of jurisdiction: Malta, Cyprus, Germany and Ireland are positioning themselves as CASP hubs, with short authorisation timelines (3 to 6 months).
- Binance: registered as a PSAN in France in 2022, with a switch to a CASP expected at the end of 2025 — intense competition among regulators to attract the big players.
- Stablecoins: since June 2024, USDC and EURC (Circle) have been issued under EMT status; USDT (Tether), not MiCA-compliant, has been delisted from several EU platforms.
- To accept crypto: a fintech must either obtain CASP authorisation or go through a partner (Bitstamp Exchange-as-a-Service, Fireblocks, Trakx).
- Point to watch: MiCA caps the daily transactions of non-euro-denominated EMTs (1M transactions / €200M per day) to limit exposure to USD stablecoins.