Regulatory Alerts2025-12-22
Instruction No. 2025-I-23 on the Legal Opinion Model for Tokens Referencing One or More Assets
The Autorité de contrôle prudentiel et de résolution (ACPR) mandates that credit institutions and token issuers referencing assets use a standardized legal opinion model to submit assessments under Articles 17 and 18 of the EU Crypto-Assets Regulation. This requirement applies to legal opinions regarding the qualification of tokens referencing one or more assets, as stipulated in the French Monetary and Financial Code. Issuers must file the completed electronic legal opinion via the ACPR portal.
PRUDENTIAL CONTROL AND RESOLUTION AUTHORITY
Instruction No. 2025-I-23 on the legal opinion model regarding the qualification of a token referencing one or more assets
The Prudential Control and Resolution Authority (ACPR), Having regard to Regulation (EU) 2023/1114 on markets in crypto-assets, in particular Articles 17 and 18; Having regard to the Monetary and Financial Code, in particular Articles L. 311-2, L. 511-1 and L. 553-1; Having regard to the opinion of the Prudential Affairs Advisory Committee of 1 December 2025, DECIDES
Article 1: Credit institutions, referred to in Article L. 511-1 of the Monetary and Financial Code, and issuers of tokens referencing one or more assets, referred to in Article L. 553-1 of the same Code, shall use the model set out in the annex to this Instruction to submit to the Prudential Control and Resolution Authority the legal opinion referred to in point (ii) of point (b) of paragraph 1 of Article 17 and point (e) of paragraph 2 of Article 18 of Regulation (EU) 2023/1114 on markets in crypto-assets.
Article 2: The legal opinion, duly completed, shall be filed in electronic format with the Prudential Control and Resolution Authority on the ACPR portal at the following address: https://acpr-autorisations.banque-france.fr
Paris, 15 December 2025 The President, Denis BEAU
Annex - Legal opinion model regarding the qualification of a token referencing one or more assets.