Instruction No. 2025-I-23 on the Legal Opinion Model for Tokens Referencing One or More Assets

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.