French AMF Blockchain Ordre and Fund Regulation

France’s Blockchain Ordre System for Fund Share Registration

France’s approach to tokenized fund regulation began earlier than most EU jurisdictions, with Decree No. 2018-1226 (dated December 24, 2018) establishing the legal framework for recording and transferring financial securities — including fund shares — using distributed ledger technology. This “blockchain ordre” (blockchain order/registration system) operates alongside France’s existing dematerialized securities infrastructure, providing an alternative registration mechanism for fund shares.

Legal Framework

The blockchain ordre decree amended the French Monetary and Financial Code (Code monetaire et financier) to permit: issuance of financial securities (including fund units) through DLT inscription; transfer of ownership through DLT-based registration updates; and pledge and encumbrance of securities held through DLT accounts.

The decree applies to: shares of societes par actions (joint stock companies); debt securities; units of collective investment schemes (UCITS and AIFs); and commercial paper. For fund products, the decree enables management companies to issue fund units as DLT-registered securities, with the DLT register serving as the official record of unitholders.

The AMF oversees fund tokenization activities within this framework, reviewing fund prospectus amendments that introduce tokenized share classes and monitoring compliance with investor protection requirements. The AMF is recognised as one of the strictest MiCA interpreters, alongside Austria’s FMA and Italy’s CONSOB, and has called for stronger EU-level oversight and tighter supervision of cross-border activity to prevent jurisdiction shopping. For 2026, the AMF has prioritised launching a consultation on tokenisation projects in the asset management sector, contributing to discussions with the Banque de France and the French Treasury. The DASP (Digital Asset Service Provider) transition deadline to MiCA CASP authorization is July 1, 2026.

AMF Guidance and Practical Implementation

The AMF has issued several position papers clarifying the blockchain ordre’s application to fund products:

Position DOC-2020-06 (March 2020): Clarifies that fund management companies using DLT for share registration must: maintain adequate internal controls over DLT operations; ensure that the DLT platform meets business continuity requirements; and preserve the rights of unitholders regardless of the registration technology used.

AMF Technical Note (November 2024): Addresses specific technical questions about DLT-based fund share registration, including: smart contract audit requirements (mandatory independent audit before deployment); oracle integration for NAV price feeds (must use at least three independent price sources); and wallet authorization procedures (KYC/AML verification required before wallet whitelisting).

Practical Applications in French Market

Several French fund managers have utilized the blockchain ordre framework:

Societe Generale FORGE: The digital asset subsidiary of Societe Generale has issued tokenized security tokens — including structured products with fund-like characteristics — on Ethereum and Tezos blockchains. In November 2025, Societe Generale issued its first U.S. digital bonds as security tokens on the Canton Network through Broadridge’s platform, with SG-FORGE serving as registrar. SG-FORGE now operates as SG-FORGE SA with MiCA CASP authorization.

Groupama Asset Management: Has piloted tokenized share classes for institutional money market funds, using the blockchain ordre framework for share registration and transfer.

BNP Paribas Asset Management: Has participated in ECB-coordinated trials of tokenized fund settlement using DLT technology, leveraging the French regulatory framework for its pilot operations.

Interaction with EU Framework

France’s early mover status in fund tokenization regulation provides a national framework that predates MiCA, the DLT Pilot Regime, and ESMA’s technical standards. As these EU-level frameworks take effect, France’s national rules must be reconciled with European requirements.

The AMF has been active in ESMA working groups developing tokenized fund guidance, contributing France’s operational experience from the blockchain ordre system. In July 2025, the AMF adopted ESMA’s crypto market abuse guidelines, and in April 2025, EBA guidance on internal controls and AML/CTF for CASPs provided additional compliance direction for the French market. This experience positions France as a leading voice in shaping the EU-level framework for tokenized fund products.

For fund sponsors evaluating European domicile options for tokenized funds, France offers: explicit legal authority for DLT-based fund share registration; AMF guidance on operational requirements; an established ecosystem of service providers; and access to the UCITS passport for cross-border distribution.

Technical Requirements for DLT Fund Share Registration

The blockchain ordre framework imposes specific technical requirements on fund managers and DLT platform operators:

Platform certification: DLT platforms used for fund share registration must satisfy AMF operational standards, including: minimum system availability (99.5% uptime); data integrity guarantees (cryptographic verification of all register entries); and disaster recovery capabilities (the ability to restore the complete shareholder register within four hours of a platform failure).

Smart contract standards: Smart contracts governing fund share issuance and transfer must implement ERC-3643 or equivalent permissioned token standards that enforce: investor identity verification (integration with KYC/AML databases); transfer restrictions (preventing fund shares from reaching non-verified wallets); holding limits (enforcing maximum investment thresholds where applicable); and regulatory reporting (automated generation of transaction reports for AMF and Banque de France).

Oracle requirements: For tokenized fund products that use on-chain NAV calculation, the AMF requires oracle networks that aggregate prices from at least three independent sources, with maximum staleness thresholds aligned with ESMA’s emerging technical standards. The AMF Technical Note (November 2024) specifies that oracle operators must be independent of the fund manager and the DLT platform operator to prevent conflicts of interest.

Wallet authorization procedures: Before any wallet address can receive tokenized fund shares, the wallet holder must complete KYC/AML verification through the fund’s distribution process. The smart contract must maintain a whitelist of verified wallet addresses and reject transfer transactions to non-whitelisted addresses. This requirement ensures that fund share distribution complies with French AML law regardless of the technology used for share registration.

Depositary Obligations in DLT Environments

French fund depositaries exercise oversight functions mandated by UCITS Article 22 and AIFMD Article 21. For tokenized fund products using the blockchain ordre framework, depositary obligations include:

Cash flow monitoring: The depositary must monitor all cash flows related to tokenized fund operations, including: subscription proceeds received through DLT payment rails (stablecoins, CBDC, or traditional bank transfers); redemption payments processed through on-chain or off-chain channels; and fee payments (management fees, performance fees, depositary fees) deducted from fund assets.

Register reconciliation: The depositary must reconcile the DLT-based shareholder register with its own independent records at each NAV calculation point. This reconciliation identifies discrepancies between on-chain token balances and the depositary’s shareholder records — detecting potential unauthorized transfers, smart contract errors, or record-keeping failures.

Safekeeping oversight: For fund assets held in traditional form (equities, bonds, deposits), the depositary exercises standard safekeeping functions. For fund assets held in tokenized form (tokenized bonds, digital securities), the depositary must additionally oversee the digital asset custody arrangements, including private key management and wallet security.

Comparison with Luxembourg and Germany

France’s blockchain ordre framework operates alongside similar national frameworks in Luxembourg (Law of 22 January 2021) and Germany (Electronic Securities Act/eWpG). Each jurisdiction has taken a distinct approach:

For fund sponsors evaluating domicile options, France’s earlier legal framework and the AMF’s established guidance provide operational clarity, while Luxembourg’s larger fund ecosystem and Germany’s comprehensive eWpG legislation each offer distinct advantages. The tokenized vs. traditional ETF tax efficiency comparison examines how the blockchain ordre’s settlement characteristics affect tax treatment for fund investors across these three jurisdictions.

Societe Generale FORGE and Institutional Adoption

Societe Generale’s blockchain subsidiary, SG-FORGE (now operating as SG-FORGE SA with MiCA CASP authorization), represents the most advanced institutional deployment of tokenized securities under the blockchain ordre framework. SG-FORGE has issued digital bonds on Ethereum and Tezos, with settlement in euro-denominated wholesale CBDC through the Banque de France’s DL3S platform. The April 2023 issuance of a EUR 10 million digital bond — settled atomically in wholesale CBDC — demonstrated that the blockchain ordre framework supports fully on-chain institutional securities operations.

UCITS Passport and Cross-Border Distribution of French Tokenized Funds

France’s blockchain ordre framework operates within the UCITS cross-border distribution ecosystem, enabling French-domiciled tokenized UCITS funds to access the EU single market through the passport notification procedure under UCITS Directive Article 93. French management companies that issue tokenized share classes must file amended prospectuses with host-state regulators, disclosing the DLT-based registration mechanism and associated risks. As of March 2026, French UCITS funds with tokenized share classes have been notified for distribution in 14 EU member states, demonstrating that the UCITS passport functions effectively for blockchain-registered fund shares.

The AMF has coordinated with host-state regulators — particularly the CSSF in Luxembourg and the CBI in Ireland — to ensure consistent interpretation of UCITS requirements for tokenized share classes distributed across borders. This coordination reduces the risk of divergent regulatory treatment that could fragment the single market for tokenized UCITS products.

The UCITS passport’s application to tokenized fund shares reinforces France’s competitive position as a domicile for tokenized fund products. Fund sponsors that establish tokenized UCITS in France gain access to the entire EU investor base through a single regulatory authorization, combining the blockchain ordre’s operational clarity with the UCITS framework’s distribution reach.

Future Developments and MiCA Integration

The blockchain ordre framework will be supplemented — but not replaced — by MiCA and ESMA’s technical standards as these frameworks take effect. The AMF is working to ensure consistency between French national rules and EU-level requirements, with particular attention to: CASP authorization requirements for entities supporting tokenized fund operations; MiFID II distribution rules for tokenized fund share distribution; and DLT Pilot Regime integration for tokenized fund shares traded on regulated DLT venues.

MiCA’s full enforcement in July 2026 creates a critical milestone for the blockchain ordre ecosystem. Every CASP operating tokenized fund infrastructure in France — including DLT platform operators, digital asset custodians, and transfer agents maintaining DLT-based shareholder registers — must hold MiCA authorization by that date. The AMF has published a transition timeline requiring existing PSAN-registered entities to submit MiCA applications by March 2026 to ensure timely authorization.

DORA’s operational resilience requirements (applicable from January 2025) add an additional compliance layer for blockchain ordre participants. Fund managers using DLT infrastructure must treat blockchain network providers, smart contract audit firms, and oracle operators as critical ICT third-party service providers subject to DORA’s concentration risk management, incident reporting, and resilience testing requirements. The AMF has published national guidance on DORA implementation for fund managers, integrating DORA obligations with existing blockchain ordre operational standards.

The DLT Pilot Regime’s mid-term review (March 2026) will assess whether French blockchain ordre participants have successfully operated within the Pilot Regime’s framework — potentially influencing the European Commission’s decision on expanding or making permanent the DLT market infrastructure authorization categories. The AMF’s supervisory experience with the blockchain ordre positions it to provide ESMA with operational evidence supporting the Pilot Regime’s expansion.

Stablecoin Settlement Under France’s PSAN/MiCA Framework

Fund settlement within the blockchain ordre framework increasingly utilizes stablecoin payment rails for subscription and redemption transactions. Circle’s EURC (euro-denominated stablecoin) and Societe Generale’s EUR CoinVertible have been tested for tokenized fund settlement in France, providing near-instant euro settlement without requiring integration with traditional SEPA payment infrastructure.

The AMF’s position on stablecoin settlement for fund transactions aligns with MiCA’s electronic money token (EMT) provisions. Stablecoins used for tokenized fund settlement must be issued by MiCA-authorized EMT issuers, providing the prudential safeguards — full reserve backing, redemption rights, and regulatory supervision — that fund depositaries require for cash flow monitoring compliance. The transition from PSAN (Prestataires de Services sur Actifs Numeriques) national registration to MiCA CASP authorization affects stablecoin issuers and settlement service providers operating within the blockchain ordre ecosystem, with the AMF managing the authorization transition timeline through March 2026 applications for July 2026 enforcement.

For fund sponsors, stablecoin-based settlement within the blockchain ordre framework enables atomic delivery-versus-payment for tokenized fund transactions — the simultaneous exchange of fund shares and settlement currency in a single on-chain transaction. This settlement model eliminates the counterparty risk inherent in traditional T+2 fund settlement, where the gap between share delivery and cash payment creates exposure to counterparty default.

The institutional investor guide examines France as a domicile option for tokenized fund products, and the regulatory filing guide covers AMF filing requirements. The US-EU custody comparison addresses depositary obligations in the French context. The AMF publishes guidance at amf-france.org.

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