Binance, Kraken, Coinbase, Bybit… if you hold an account on a foreign platform and have never declared it to the French tax authorities, you are exposed. QOMIT regularizes the declaration of your accounts for a fixed fee, with a process designed to move fast.
This offer covers only the reporting obligation for the accounts themselves (form 3916-bis, the French declaration of accounts held abroad). If your crypto income tax returns also need to be regularized, we also practice in this area and can offer you a dedicated engagement.
One point matters more than anything: as long as the tax authorities have not written to you, your filing is a voluntary regularization — what English-speaking practitioners would call a voluntary disclosure. That is a decisive advantage: a situation regularized on your own initiative is, in most cases, treated more favorably than an omission discovered during a tax audit.
Any account opened, held, used or closed on a foreign crypto platform must be declared each year to the French tax authorities (form 3916-bis). Failure to declare is penalized, and the exposure grows over time.
As a matter of law: the reporting obligation stems from Article 1649 bis C of the French Tax Code (CGI) and the fine from Article 1736, X of the CGI; the increased amount of €1,500 applies where the market value of the account exceeded €50,000 during the year.
An illustrative example: the potential fines on 3 undeclared crypto accounts, opened several years ago, over a 10-year limitation window.
For income tax, the French tax authorities can in principle go back over the last three years (Article L. 169 of the French Book of Tax Procedures). But where the reporting obligations for accounts held abroad have not been met, this reassessment window is extended to ten years.
In practice: an account opened in 2017 and never declared keeps open years you thought had long been time-barred — and that exposure does not close on its own. This is also why regularizing the accounts is often the first step of coming into compliance: it contains past exposure rather than letting it build up.
And what changes everything: DAC8.
DAC8 (Directive on Administrative Cooperation) is the European directive which, since January 1, 2026, has required crypto-asset exchange platforms to collect the identity and transactions of their users, with a view to automatic transmission to the French tax authorities from 2027.
The “no one will know” logic no longer exists: the question is no longer whether your account will be identified, but when.
In concrete terms, the timeline is already set (Directive (EU) 2023/2226):
Platforms (crypto-asset service providers) collect the identity, tax identification number (NIF) and transaction flows of their users
First transmission of data by the platforms to the DGFiP, the French tax administration (2026 transactions)
First automatic exchange between EU tax administrations
Roll-out of the OECD’s CARF: among the committed jurisdictions, the United Kingdom, Switzerland, the United Arab Emirates, Singapore and Hong Kong
This scenario is not theoretical: it is exactly what happened with foreign bank accounts. Since 2019, the French tax authorities have been sending letters to holders of accounts revealed by the automatic exchange of bank data (CRS), inviting them to regularize. The same well-oiled mechanism will apply to crypto data from 2027.
Hence the importance of timing: receiving a letter from the tax authorities closes the most favorable window. Before any letter, the regularization is fully voluntary: it allows you to request that the penalties be waived. Acting before the first transmission in 2027 means choosing the moment and the conditions of coming into compliance.
A direct discussion with your lawyer to assess your situation: the accounts concerned, the platforms, and the years potentially exposed within the limitation period (10 years).
PrécisionNo account statements or transaction history are needed: only the identification details of each account (platform, opening date, current status), shared through an end-to-end encrypted tool. All exchanges are covered by the lawyer’s professional secrecy.
ConfidentialitéQOMIT drafts and files the corrective declarations (3916-bis) with the French tax authorities, together with a cover letter requesting a discretionary waiver of the penalties (“remise gracieuse”).
Courrier de remise gracieuse inclusYou receive proof of filing for your corrective declarations.
What filing changes right away: your reporting position is restored, with official proof, and your exposure stops growing year after year. The tax authorities may then respond to the waiver letter, demand payment of the fines, or not react; each situation calls for an appropriate response, and post-filing follow-up is handled, where necessary, as a separate engagement.
The fee per account decreases as the file grows, regardless of the number of years involved for the accounts being regularized.
The fixed fee covers only the preparation and official filing of your declarations by QOMIT. Post-filing follow-up (any reminders, exchanges with the tax authorities) is not included and is handled as a separate engagement if necessary.
This offer covers the declaration of the accounts only. If gains also need to be regularized, we will offer you our full, tailor-made regularization engagement (quote after the assessment).
Book an appointment →Your file is handled under the responsibility of Maître Stéphanie Némarq-Attias, a tax lawyer for 17 years and the founder of QOMIT, whose practice is dedicated to the taxation of digital assets. She has appeared on BFM Crypto and BSmart and in Les Échos.
The taxation of digital assets (DeFi, staking, foreign platforms, NFTs) has been Stéphanie Némarq-Attias’s main area of activity since 2017, within a firm that also advises on personal wealth, international and corporate taxation.
Your exchanges go through an encrypted sharing tool and are covered by the lawyer’s professional secrecy, at every step.
The collection of information is streamlined to move fast; the filing and the strategy of your file remain personally handled by Stéphanie Némarq-Attias.
It all depends on the nature of the letter. An information letter or an invitation to regularize is not the opening of a tax audit: compliance initiated after receiving it retains, for the most part, the benefit of a voluntary approach. It does, however, require a methodical response — and checking that the letter is genuine, as phishing campaigns impersonating the DGFiP are circulating on this very topic.
If, on the other hand, an audit is already under way (an in-depth examination of your personal tax situation (ESFP), a request for justifications, a “proposition de rectification” — reassessment notice), the framework changes: the regularization is then negotiated within the procedure itself.
No — this offer deals only with the reporting obligation for the accounts (form 3916-bis). If you also need to regularize undeclared gains, that is a complementary, tailor-made engagement (reconstructing transactions, computing the gains, negotiating penalties), to be discussed with your lawyer during the assessment.
No — it is fully included in the fixed fee indicated above.
The timeline depends on the number of accounts and years concerned, but the process is designed to be significantly faster than a traditional engagement billed by the hour.
A voluntary regularization is, in the vast majority of cases, treated more favorably by the tax authorities than an omission discovered during an audit, through the French “droit à l’erreur” (the right to correct in good faith, under the Essoc law). This point is explained in detail during the assessment.
The assessment determines the years actually exposed, within the limitation period: three years as a rule, but ten years where accounts held abroad have not been declared. In practice, the regularization covers the non-time-barred years during which each account was opened, held, used or closed.
Filing 3916-bis forms yourself for past years is technically possible. The value of going through a lawyer lies in the framing of the approach: the exact scope of years and accounts to cover, how the filing fits with the position on gains, a reasoned letter requesting the waiver of penalties, and exchanges covered by professional secrecy.
Today, the tax authorities can obtain information on a targeted basis (statutory requests for information, international assistance requests, cross-checking of bank flows). From June 15, 2027, transmission will become automatic and systematic for the platforms covered by DAC8, then by the CARF for the main non-EU jurisdictions.
Your exposure keeps growing automatically: the fines add up per account and per year (capped at €10,000 per annual declaration, with the cap applying again each year), and the ten-year limitation period keeps older years open. Above all, once your data has been transmitted under DAC8 and a letter received, the window for a voluntary regularization — the most favorable one — closes.
Yes. Its balance does not matter: an account abroad must be declared as long as it existed at any point during the year, even if closed or nearly empty. A forgotten account on a platform you left years ago therefore falls within the scope of the regularization — this is precisely what the assessment is designed to identify.