Fintech 2026

FRANCE Trends and Developments Contributed by: Marie Frisch and Estelle Rigal-Alexandre, Soulier Bunch

and an extension planned for SMEs by 2025 via the Facturae system; and • Poland has used a centralised system (KSeF) since 2022, allowing for real-time control of transactions. In summary, electronic invoicing represents a key mile - stone in the digitalisation of the economy. Its success will rely on the support provided to businesses and on the ability to ensure a secure, efficient and interoper - able system. The reform is part of a broader drive for modernisation, in which digitalisation is becoming a key driver of competitiveness and transparency. Transition to MiCA In France by June 2026: a European Framework set to Reshape the Crypto- Asset Market The EU has reached a landmark milestone with the adoption of MiCA, the world’s first comprehensive regulatory framework for crypto-assets and digital assets. Having entered into force in June 2023 and becoming progressively applicable in France from 2024, MiCA aims to protect investors, combat fraud and support innovation in a sector historically marred by limited transparency and significant volatility. As part of this transition, France has opted for an 18-month transitional period during which provid - ers authorised under the PACTE regime (the national framework for digital asset service providers) may continue their activities without holding MiCA authori - sation. The deadline of 30 June 2026 constitutes a firm and non-extendable cut-off date for the full integration of the Regulation into the French legislative framework. For market participants, MiCA imposes more strin - gent requirements but also provides crypto-assets with renewed legitimacy in Europe. MiCA applies to three main categories of crypto- assets. The first is standard crypto-assets (such as Bitcoin and Ether), for which trading platforms are now required to publish a detailed White Paper for each listed asset, outlining its operation, associated risks and governance mechanisms. They must also inform clients of the risks of capital loss, volatility and applicable fees, while ensuring the segregation of cli -

ent funds from their own assets to prevent conflicts of interest. Secondly, stablecoins (such as USDT and USDC), which are crypto-assets pegged to fiat currencies, lie at the heart of MiCA due to their pivotal role in trading and payments. MiCA requires issuers to maintain a 1:1 reserve ratio for tokens in circulation, which must be subject to regular audits. These reserves must be segregated from the issuer’s other assets and kept in liquid form. In addition, “significant” stablecoins – defined as those with more than one million users or a market capitalisation exceeding EUR5 billion – are subject to even more stringent requirements, includ - ing supervision by the European Central Bank. Final - ly, algorithmic stablecoins, which rely on algorithmic mechanisms rather than tangible reserves, are prohib - ited within the EU. Thirdly, MiCA covers utility tokens and other innovative digital assets. Issuers are required to publish a White Paper, which must be approved by national regulators (the Autorité des marchés financiers in France). Their compliance must be verified by trading platforms prior to being listed. Marketing communications are also strictly regulated and must be clear, non-misleading, and include mandatory risk warnings. The FIDA Regulation: A Major New Step in the Regulation of Financial Services The proposed FIDA Regulation is a major EU initiative aimed at regulating access to financial data relating to consumers and businesses. Adopted as part of the EU’s digital finance strategy, this Regulation fol - lows on from ongoing efforts to modernise the finan - cial sector, strengthen competition and improve data protection. Its primary objective is to establish a har - monised legal framework enabling users to securely share their financial data with authorised third parties, while ensuring control over this data and its confiden - tiality. The FIDA Regulation is rooted in several regulatory and technological developments. First, it builds on the success of the Second Payment Services Directive (PSD2), which introduced “open banking” into Europe in 2018, by allowing fintech companies and third-par - ty banks to access payment account data – subject

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