CARF: The Senate Targets Your Foreign Cryptos for Taxation

The tax authorities, in long-range mode. The Senate is examining on Tuesday, October 27, starting at 2:30 PM, the bill that allows France to approve the CARF, the OECD agreement on the automatic exchange of crypto data. The principle can be summarized in one sentence: Platforms around the world will report their clients to their own tax authorities, and the files will end up in the country of residence of each individual.

The timing is humorous. The deputies are indeed resuming the examination of the 2027 budget on the same day. They are expecting a tax on conversions to stablecoins and the obligation to declare large wallets. Bercy will soon have the data and perhaps the rules to use it. Key points of this article:

• The Senate has examined the bill allowing France to approve the OECD CARF agreement, aimed at the automatic exchange of crypto data globally.
• This international mechanism will require non-EU crypto platforms to report their clients' information, with a phased implementation until 2029.

The CARF Explained Without Tax Jargon

The mechanism already exists for your bank accounts. Since 2017, the Common Reporting Standard (CRS) of the OECD requires foreign banks to report accounts held by non-residents. A French citizen who maintains an account in Geneva is known to the DGFiP without having asked anyone.

The system is based on reciprocity. France sends to Bern what it knows about the accounts of Swiss residents in France, and Switzerland reciprocates. Each country only communicates with its own tax authority, which then sorts by tax nationality.

Cryptos were escaping this net. An exchange based in Singapore is not a bank, and the account a French citizen opened there did not appear in any file. Therefore, the OECD published the Crypto-Asset Reporting Framework (CARF) in 2022, applying the same logic to digital assets.

Each concerned provider collects the identity of its clients and their tax residence. It then reports for each crypto the number of transactions and their total value over the year. Purchases against euros or dollars, exchanges between cryptos, and outgoing transfers are included in the report.

What the Senate is Voting on This Tuesday

Bill No. 921 consists of two articles. The first authorizes the approval of the multilateral agreement on the CARF, signed by France on November 26, 2024, in Asunción with 48 other states and territories. The second concerns an addendum to the banking agreement that circulates account data since the income of 2016.

Why must Parliament get involved? Article 53 of the Constitution requires its approval for this type of international commitment, and without it, France cannot activate the exchanges. However, the senators will not rewrite anything. An international agreement cannot be amended in Parliament. It is approved or rejected as a whole, here after thirty minutes of speaking time divided among the groups.

A Tight Schedule

The government initiated the accelerated procedure as soon as the text was submitted on July 27. The examination is therefore limited to one reading per chamber. The finance committee adopted it without modification on October 21, based on report No. 83 from Senator Emmanuel Capus.

Just before, the chamber examines the amendment to the France-India tax convention of 1992. India is one of the four jurisdictions that have made no commitments on the CARF, along with El Salvador, Georgia, and Vietnam. A process is underway with New Delhi, according to the report.

The text will then go to the National Assembly. Its legislative file does not yet set any examination date.

DAC8 for Europe and CARF for the Rest of the World

In the European Union, the collection has already begun. From January 1, 2026, crypto platforms established in the EU will record your data under the DAC8 directive, transposed by the finance law for 2025. The first declaration to the DGFiP will cover transactions from 2026. DAC8 is actually the European version of the CARF. Both texts require the same data, but DAC8 only applies among the 27 member states.

The CARF exports this mechanism outside of Europe. The Capus report lists 77 jurisdictions committed to applying it by September 14, 2026, according to a schedule spread over three years.

• 46 jurisdictions for initial exchanges in 2027, including France
• 27 in 2028, among which are Switzerland and Singapore
• 4 in 2029, including the United States, committed without having signed the multilateral agreement

Japan and the United Kingdom are among the 56 signatories of the agreement. However, the signature alone does not trigger anything. << The mere signing of the agreement does not automatically make exchanges operational >>, writes the rapporteur, and each pair of countries must still activate their own.

France will also set its conditions. An annex will specify its data protection requirements, and jurisdictions that do not comply will receive nothing. Emmanuel Capus made this response in committee to Senator Nathalie Goulet, who was concerned after the data leak that occurred at the DGFiP.

The Banking Precedent in Numbers

On the banking side, France received information in 2025 about 11.6 million accounts held abroad. Their total balances reached 456 billion euros, coming from 109 jurisdictions. The first campaign, ten years earlier, counted 1.16 million.

For crypto, the expected volume remains << difficult to assess at this stage >> according to the rapporteur. Adan estimated at the beginning of 2025 that 10% of French adults held crypto assets, worth between 21 and 26 billion euros.

What Changes for a French Holder

It all depends on where your cryptos are stored. Four situations cover the majority of holders.

• European Platform. You buy on an exchange licensed in France or elsewhere in the EU. DAC8 already transmits your operations from 2026, and the CARF adds nothing.
• Swiss or Singaporean Platform. Your operations from 2027 will go to the local administration, which will relay them to the DGFiP in 2028 with your name, address, and tax number.
• American Platform. The United States will only exchange starting in 2029, based on 2028 data.
• Wallet for which you hold the keys. No intermediary, therefore no automatic declaration. Courson's amendment would create a simple reporting obligation beyond 100,000 euros, with no additional tax.

In each case, the tax authorities receive the statement within nine months following the end of the relevant year.

Your obligations, however, do not change. Any digital asset account opened abroad must already be reported on form 3916-bis, under penalty of a 750 euro fine per forgotten account. The penalty increases to 1,500 euros when the value of accounts exceeds 50,000 euros in the year.

For reference, the 3916-bis indicates the existence of an account. Form 2086 calculates the tax on your capital gains. These are two distinct declarations, and the CARF allows for verification of both.

What changes are the means of control. The DGFiP will be able to cross-check declared accounts and capital gains reported on form 2086 with the flows sent by the platforms themselves. An account opened in Zurich and forgotten on the 3916-bis will show up in the files received in 2028.

Self-hosted wallets remain outside the system. Without an intermediary, no one declares anything to anyone. This is precisely the gap that the 2027 budget aims to close.

The 2027 Budget Writes the Next Chapter

The CARF provides the data. The tax rules are currently being debated in the National Assembly. The finance committee rejected the revenue part of the finance bill on October 9, so the chamber is starting from the government's draft.

The flat tax of 31.4% on crypto capital gains remains unchanged. No amendments have affected it.

Tax on Conversions to Stablecoins

Stablecoins are at the center of the debate. Adopted in session on October 16 by 38 votes to 37, the amendment by MP Nicolas Sansu (GDR) makes the conversion of a cryptocurrency to a stablecoin taxable starting January 1, 2027. Currently, converting bitcoin to USDC does not trigger any tax as long as you do not convert back to euros. Exchanges between cryptocurrencies benefit from a tax deferral, and only the exit to official currency or the purchase of goods is taxed.

With this text, a capital gain of 40,000 euros converted to stablecoin would cost 12,560 euros. It only targets electronic money tokens as defined by MiCA, meaning stablecoins backed by a single currency and approved in Europe. This definition would exclude USDT, which has no MiCA approval.

Unhosted Wallets and Exit Tax

Charles de Courson (LIOT) is also proposing the declaration of unhosted wallets exceeding 100,000 euros held as of December 31. This obligation is purely declarative. It does not create any tax and serves to inform the tax authorities of the existence of the wallet. A failure to declare could result in a fine of up to 10,000 euros. Two versions of an exit tax are also on the table. The principle is to tax your unrealized gains on the day you leave France, even if you have not sold anything. Nicolas Sansu's version targets holders of more than 800,000 euros in cryptocurrencies, while the other is supported by the socialist group.

The government's text also proposes a fine of 10,000 euros per request. This targets platforms that refuse to provide their documents to the tax authorities. Everything depends on the solemn vote on the revenue part. Debates are expected to conclude on Monday, November 2, and the vote is scheduled for Tuesday afternoon, November 3, in the Assembly. A rejection would invalidate the entire proposal. This is what happened on October 23 to the revenue part of the Social Security budget, which was dismissed by 115 votes to 1.

For France, the first CARF exchanges are planned for 2027 with the 45 other jurisdictions in the first wave. They will cover the year 2026, and your operations from the last ten months are already included in the scope.