France’s top court rejects emergency challenge to DAC8 crypto decree

France’s Council of State denied an emergency request filed by crypto service providers Bull Bitcoin and Paymium to suspend the French decree that enacts the EU’s DAC8 crypto tax reporting rules. The court said the plaintiffs had not demonstrated sufficient urgency to justify a temporary freeze of the measure.

Reason for denial

The court held that a mere possibility of a low‑probability risk does not constitute an urgent situation. Bull Bitcoin had argued that centralising user data for tax reporting could create security risks if the information were compromised, but the judges found the urgency claim unsubstantiated.

Ongoing annulment case

The emergency request was separate from a broader legal challenge launched earlier this year that seeks to annul the French implementation of DAC8. Bull Bitcoin says the main case questions the government’s authority to adopt the decree and raises concerns about fundamental rights and EU privacy protections. The court has not yet ruled on the merits of that challenge.

Background on DAC8

DAC8 entered into force across the EU on 1 January 2026, extending automatic tax‑information exchange to crypto assets. Service providers must collect detailed user information—including names, addresses, tax IDs and transaction data—for the 2026 calendar year, with the first exchange of data scheduled for 2027.

Security concerns in France

France has seen a rise in physical attacks targeting cryptocurrency holders and their families. Authorities reported 77 crypto‑related incidents in 2026 up to early July, compared with 45 in the previous year. Analysts have linked the concentration of attacks to the potential exposure of personal data, though direct causality has not been proven.