Bull Bitcoin and Paymium did not obtain the immediate suspension of DAC8 in France. The Council of State rejected their summary judgment against the French decree which organizes the collection and transmission of data on crypto-asset transactions. However, the court did not rule on the merits of the case. The appeal seeking the annulment of Decree No. 2025-1276 continues.
In brief
- The Council of State rejects the request for urgent suspension filed by Bull Bitcoin and Paymium.
- The appeal for the complete annulment of decree DAC8 remains open.
- Operations carried out since January 1, 2026 will have to supply the first declarations in 2027.
The Council of State refuses immediate suspension
Bull Bitcoin had already been challenging DAC8 before the Council of State since February. Tremplin.io detailed in July the appeal launched by the company against the French decree. A new emergency procedure was then initiated with Paymium. Objective: to have the decree suspended while the main file is examined.
The Council of State did not follow. The applicants have not demonstrated sufficient urgency to justify an immediate freezing of the text. The court therefore did not validate or reject their arguments on the legality of DAC8. She only refused the provisional suspension.
Bull Bitcoin rightly emphasizes this distinction. Its appeal for annulment continues before the highest French administrative court. The contested text is Decree No. 2025-1276 of December 19, 2025. It defines the reporting obligations and due diligence imposed on crypto-asset service providers in France. It came into force on January 1, 2026.
DAC8 already collects operations carried out since January
The calendar has therefore not changed. The transactions concerned are those carried out since January 1, 2026. They must be the subject of the first declarations in 2027. The French tax administration has already published technical documents intended for the transfer of information under DAC8 and the Crypto-Asset Reporting Framework, or CARF.
The service providers concerned must identify users and transmit certain information related to their operations. The mechanism then provides for automatic exchanges between European tax administrations.
France is also working on extending this system beyond the European Union. Tremplin.io explained in August that CARF could allow the sharing of crypto data with dozens of other jurisdictions.
For Bull Bitcoin and Paymium, the problem is not only about taxation. The two companies say that a foundation linking identity, residence and activity on digital assets can become a particularly sensitive target in the event of a leak or illegitimate access. Bull Bitcoin has been defending since the start of his appeal the idea that systematic collection exposes holders more than a targeted tax request. This is the applicants’ argument, not a conclusion of the Council of State. The decree therefore remains applicable while the legal debate continues.
Crypto: physical risk remains at the center of the appeal
The subject is particularly sensitive in France. The crypto sector has seen a series of attacks, kidnappings and kidnapping attempts this year. At the end of June, French authorities had recorded 77 violent cases linked to the sector since the start of 2026, with around 200 suspects arrested, according to figures reported by Tremplin.io after a presentation by the Minister of the Interior. France has since strengthened its protection system for professionals and their loved ones.
Bull Bitcoin and Paymium use this context to support their argument about data security. The Council of State did not consider that this risk was sufficient, at this stage, to characterize the urgency necessary for a suspension.
DAC8 therefore continues its schedule. For service providers, the first important deadline will arrive in 2027 with declarations relating to transactions in 2026. For Bull Bitcoin and Paymium, the next challenge is elsewhere: obtaining a decision on the legality of the French decree. This battle is not over.
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