🇫🇷 France vs 🇵🇹 Portugal: crypto licensing compared
France and Portugal take recognisably different routes to crypto authorisation. In France the route is the MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services. overseen by AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team.; in Portugal it is the MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. under Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.). The two regimes differ on 6 of 9 tracked decision dimensions, including timeline to authorisation and local substance. The free columns below are open to everyone; the decision figures unlock with a pass, each one dated and sourced.
France: verified 2026-07-03 · Portugal: verified 2026-07-01
| Dimension |
🇫🇷 France
partly open
Verified 2026-07-03
|
🇵🇹 Portugal
partly open
Verified 2026-07-01
|
|---|---|---|
| Licence type | MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services. | MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. |
| Regulator | AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team. | Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.) |
| Capital requirement | France capital requirement is locked. Unlock with the £349 pass. | Portugal capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | France timeline to authorisation is locked. Unlock with the £349 pass. | Portugal timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | France local substance is locked. Unlock with the £349 pass. | Portugal local substance is locked. Unlock with the £349 pass. |
| Application cost | France application cost is locked. Unlock with the £349 pass. | Portugal application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | France ongoing cost is locked. Unlock with the £349 pass. | Portugal ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | France passporting is locked. Unlock with the £349 pass. | Portugal passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | France mica casps approved is locked. Unlock with the £349 pass. | Portugal mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | France key restrictions is locked. Unlock with the £349 pass. | Portugal key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | France used the full 18-month transition, ending 1 Jul 2026 (today). Deblock first CASP (May 2025), SG-Forge (Oct 2025); ~18 CASPs authorised by 28 May 2026. AMF adopted ESMA staff knowledge/competence guidelines (Mar 2026). | Lei 69/2025 (MiCA) + Lei 70/2025 (Travel Rule) published 22 Dec 2025 - ~1 year late. Legacy-VASP transitional window closes 1 Jul 2026 (today). Few Portugal-AUTHORISED CASPs so far. |
| Difficulty rating | France difficulty rating is locked. Unlock with the £349 pass. | Portugal difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 6 of 9 tracked decision dimensions, including timeline to authorisation and local substance. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇫🇷 France (verified 2026-07-01): France used the full 18-month transition, ending 1 Jul 2026 (today). Deblock first CASP (May 2025), SG-Forge (Oct 2025); ~18 CASPs authorised by 28 May 2026. AMF adopted ESMA staff knowledge/competence guidelines (Mar 2026).
🇵🇹 Portugal (verified 2026-07-01): Lei 69/2025 (MiCA) + Lei 70/2025 (Travel Rule) published 22 Dec 2025 - ~1 year late. Legacy-VASP transitional window closes 1 Jul 2026 (today). Few Portugal-AUTHORISED CASPs so far.
Quick answers
Who regulates crypto licensing in France and Portugal?
France: AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team.. Portugal: Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.).
What licence do you need in France compared with Portugal?
In France the authorisation route is MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services.; in Portugal it is MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full France vs Portugal comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /crypto/compare/france-vs-portugal.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.