FRANCE Trends and Developments Contributed by: Hubert de Vauplane, Arnaud Grünthaler and Hugo Bordet, Morgan, Lewis & Bockius LLP
Conclusion The French blockchain landscape in 2026 reflects a broader transition from crypto-market regulation towards the construction of regulated digital financial infrastructure. France is no longer positioning itself primarily as an early crypto experimentation jurisdiction. Instead, French authorities now seek to integrate blockchain technologies into regulated financial, payment and settlement infrastructures compatible with European prudential supervision, monetary stability and market- infrastructure objectives. The common thread linking these developments is the growing institutionalisation of blockchain within the architecture of European finance.
Importantly, the French approach focuses on govern- ance and effective operational control over DeFi pro- tocols, including upgrade powers, administrative keys and governance structures. In parallel, French industry actors, including ADAN, advocated a functional definition of “full decentralisa- tion” under MiCA based on effective control, custody and governance powers rather than purely formal or technical criteria. These discussions reflect broader European tensions between intermediary-based financial supervision and the decentralised operational logic of blockchain pro- tocols. At the same time, they illustrate the emergence of a specifically French approach to DeFi regulation focused on governance, accountability and opera- tional reliability rather than purely formal claims of decentralisation. France experiments with bespoke blockchain regulation France also became one of the first European jurisdic- tions to establish a dedicated regulatory framework for blockchain-based gaming involving monetisable digital objects. In February 2026, France implemented the decrees organising the experimental framework applicable to jeux à objets numériques monétisables (JONUM). The framework creates a sui generis cat- egory positioned between gambling regulation and crypto-asset regulation and supervised by the Autorité Nationale des Jeux (ANJ). The implementation of the JONUM regime illustrates a broader French regulatory tendency: rather than applying existing legal categories mechanically to blockchain-based activities, French authorities favour bespoke or functionally adapted regulatory frame- works.
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