The update directly addresses regulatory authorization requirements for crypto-asset service providers under MiCA, establishing mandatory licensing and approval procedures for financial advisers offering crypto-asset advice.
Mandatory inheritance: Cryptocurrency is a child of Technology, so Technology must be raised as the secondary tag.
Product
The update addresses regulatory requirements for advisers providing recommendations on crypto-assets as a service, which relates to the Crypto Assets product type, though the focus is primarily on advisory service delivery and authorization rather than the crypto-asset product itself; flagged for human review due to confidence below 0.75.
The update also references advice on financial instruments with crypto-asset underlying assets including alternative investment funds and crypto-asset-linked debt securities, which touches on structured products and investment advisory services; flagged for human review as the connection is indirect and confidence is below 0.75.
Obligation
The update clarifies authorization and approval requirements for financial investment advisers seeking to provide crypto-asset advice under MiCA, establishing which entities must obtain CASP status and which are exempt, which is fundamentally an Approval and Certification obligation.
The update provides guidance on eligibility criteria and carve-outs (e.g., non-personalised information, crypto-asset-linked instruments) that determine whether an FIA must seek CASP authorization, which relates to Eligibility Assessment, though the primary focus is on the approval requirement itself.
Activity
The update concerns the provision of advice on crypto-assets by investment advisers under MiCA, which falls within the crypto asset services taxonomy activity.
The update also addresses investment advice obligations and the distinction between personalised crypto-asset advice (requiring CASP status) and non-personalised information dissemination, making investment advice a secondary consideration; flagged for human review given the lower confidence and the primary focus on crypto-asset service authorisation rather than traditional investment advice mechanics.
Themes
The update centers on mandatory authorization and conduct requirements for financial advisers providing advice on crypto-assets under MiCA, which is the core Crypto Regulation theme.
The clarification of when personalized advice on crypto-assets requires authorization versus when non-personalized information dissemination does not reflects the Suitability and Appropriateness theme, flagged for human review given the moderate confidence.
Functions
Wealth management advisers must interpret and apply the new MiCA authorization requirements to determine when CASP status is mandatory versus optional for crypto-asset advice, directly impacting their advisory scope and compliance obligations.
Compliance functions must monitor and interpret the AMF's updated doctrine to ensure advisers operate within the correct authorization framework and escalate any borderline crypto-asset advice scenarios through governance.
2026-08-05 10:33:15·csoo@vixio.com
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With the entry into application of the MiCA Regulation and the end of its transitional period, the provision of the service of advice on crypto…
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TITLE: France's Financial Markets Authority Updates Crypto-Assets Advice Doctrine for Investment Advisers
BODY:
On August 4, 2026, the Autorité des Marchés Financiers (AMF) updated its doctrine regarding the provision of advice on crypto-assets by financial investment advisers (FIAs) following the entry into application of the Markets in Crypto-assets Regulation (MiCA) and the end of its transitional period.
Under MiCA, the provision of advice on crypto-assets is now subject to mandatory authorisation at the European level as a crypto-asset services provider (CASP). This represents a significant change from the previous regime, where FIAs could provide advice on digital assets either with optional approval as a digital asset services provider (DASP) or without such approval under general wealth management advice activities. The scope of advice on crypto-assets under MiCA is broader than investment advice under the Markets in Financial Instruments Directive (MiFID II), as it encompasses not only transactions in crypto-assets but also advice on the use of crypto-asset services.
The AMF clarified that FIAs are not eligible for the notification procedure available to certain already-authorised entities, such as investment services providers. To address questions from FIAs, the AMF added a new question-and-answer section to its Position-Recommendation DOC-2006-23, which supplements guidance from the European Securities and Markets Authority (ESMA). The update provides non-exhaustive examples of situations in which FIAs do or do not require CASP status. Notably, FIAs do not need CASP authorisation when disseminating non-personalised information about crypto-assets or crypto-asset services to the public, or when providing advice on financial instruments with crypto-asset underlying assets, such as alternative investment funds or crypto-asset-linked debt securities.
The AMF Position-Recommendation DOC-2006-23 is available on the AMF website.
Advice on crypto-assets: the AMF updates its doctrine in relation to FIAs | AMF Skip to main content Print from the website of the AMF Merci de désactiver le bloqueurs de pub pour visualiser cette vidéo. Home News & Publications News Advice on crypto-assets: the AMF updates its doctrine in relation to FIAs News Investment advice Advice on crypto-assets: the AMF updates its doctrine in relation to FIAs Partager par mail Partager sur Twitter Partager sur Linkedin Partager sur Facebook 04 August 2026 Print Download Advice on crypto-assets: the AMF updates its doctrine in relation to FIAs With the entry into application of the MiCA Regulation and the end of its transitional period, the provision of the service of advice on crypto-assets is now subject to specific authorisation and compliance with the rules laid down at European level. In its doctrine, the Autorité des Marchés Financiers (AMF) specifies the situations in which a financial investment advisor (FIA) is required to obtain crypto-asset services provider (CASP) status in order to provide the service of advice on crypto-assets. Background In 2022, the AMF specified the rules applicable to FIAs when they acted in relation to digital assets (now called crypto-assets). At that time, providing advice on digital assets to investors was subject to optional approval. Thus, when an FIA had obtained approval as a digital asset services provider (DASP) to provide this service of advice o, digital assets to investors, said activity was then governed by the rules relating to this service. In the absence of such approval, this activity was considered to fall under ‘other wealth management advice activities’ and remained subject to compliance with the organisation and conduct of business rules of the FIA regime. Under the MiCA Regulation, providing the service of advice on crypto-assets is now subject to mandatory authorisation at the European level, as a CASP. This authorisation can be obtained by the issuance of an authorisation, or, for certain entities that are already authorised, particularly investment services providers, by a notification procedure. FIAs are not eligible for this procedure. The entry into application of this new MiCA regime and the end of the transitional period now render the clarifications provided in 2022 obsolete. As specified in Article 3 1.24) of Regulation (EU) 2023/1114, the service of advice on crypto-assets is defined as ‘offering, giving or agreeing to give personalised recommendations to a client, either at the client’s request or on the initiative of the crypto-asset service provider providing the advice, in respect of one or more transactions relating to crypto-assets, or the use of crypto-asset services’. The scope of advice on crypto-assets is broader under MiCA than that of investment advice under MiFID II, which covers transactions in financial instruments. Advice on crypto-assets includes advice on the use of crypto-asset services. Consequently, providing it requires compliance with the new requirements under MiCA. Finally, ESMA recently published a Q&A on the perimeter of the advice service under MiCA. Clarifications provided by the AMF In response to the need for clarification, expressed in particular by FIAs, the AMF is adding a new Q&A to its Position-Recommendation DOC-2006-23. On the one hand, this relays ESMA’s Q&A from which it is taken and, on the other, supplements it with non-exhaustive examples of situations in which an FIA does or does not need CASP status. It outlines the criteria to be taken into consideration when defining a personalised recommendation to fall within the perimeter of advice on crypto-assets under MiCA and provides examples of advice on crypto-assets. Conversely, it cites, among the situations in which CASP authorisation is not necessary, on the one hand, the dissemination of information relating to crypto-assets or CASPs, which is not personalised and is intended for the public, and on the other hand, the provision of advice on financial instruments, even if the underlying assets are crypto-assets (AIFs, crypto-asset-linked debt securities, etc.). Find out more AMF Position-Recommandation DOC-2006-23: Questions and answers on the rules that apply to financial investment advisers (in French only) ESMA Questions and Answers MiCA Regulation Keywords MiCA Asset management On the same topic Subscribe to our alerts and RSS feeds News MMF 30 July 2026 Money market funds: the ANC has confirmed the presumption of classification as "cash equivalents" Money market funds: the ANC has confirmed the presumption of classification as "cash equivalents" Partager sur Twitter Partager sur Linkedin Partager sur Facebook News Asset management 24 July 2026 The AMF has published an updated version of its guide for UCITS and AIF depositaries The AMF has published an updated version of its guide for UCITS and AIF depositaries Partager sur Twitter Partager sur Linkedin Partager sur Facebook News Asset management 23 July 2026 The Autorité des Marchés Financiers (AMF) is updating its doctrine in light of the recent revision of the European Benchmarks Regulation and the new regulatory framework for… The Autorité des Marchés Financiers (AMF) is updating its doctrine in light of the recent revision of the European Benchmarks Regulation and the new regulatory framework for deposits with the Caisse des Dépôts et Consignations Partager sur Twitter Partager sur Linkedin Partager sur Facebook Legal information: Head of publications: The Executive Director of AMF Communication Directorate. Contact: Communication Directorate – Autorité des marches financiers 17 place de la Bourse – 75082 Paris cedex 02 Revenir en haut de page