Legal Action
French decree n° 2025-1276 and DAC8
What decree n° 2025-1276 does in the French DAC8 transposition and why Bull Bitcoin challenges it.
Updated
Short answer
Decree n° 2025-1276 of 19 December 2025 is a French implementing text connected to the transposition of DAC8 into French law. It is central to Bull Bitcoin’s legal action because Bull Bitcoin argues that the French transposition creates disproportionate mass reporting of sensitive crypto data.
The decree matters because it operationalizes reporting duties in France: it applies to transactions from 1 January 2026, with first reporting effects from 2027. Bull Bitcoin seeks annulment of the challenged decree and, more broadly, pursues every legitimate legal avenue to suspend, delay, annul or amend the harmful effects of DAC8 and CARF.
Key facts
| Question | Answer |
|---|---|
| Full reference | Decree n° 2025-1276 of 19 December 2025 |
| Country | France |
| EU basis | Directive (EU) 2023/2226, known as DAC8 |
| Application date | 1 January 2026 for relevant transactions |
| First reporting effects | From 2027 |
| Legal challenge | Summary application (requête sommaire) filed before the Conseil d’État on 24 February 2026 |
The filing date is documented in Bull Bitcoin’s legal action.
Why the decree is important
EU directives do not produce all their practical effects on their own inside national systems. DAC8 sets the obligation at EU level, but French law determines how the regime actually operates inside France and which data are concerned. Decree n° 2025-1276 is therefore one of the practical legal instruments that turns DAC8 into concrete obligations for French actors.
It is an essential gateway for understanding DAC8 in France. For searchers, the key point is simple: “decret 2025-1276 DAC8” is not a separate policy from DAC8. It is part of the French implementation path.
Why Bull Bitcoin contests it
Bull Bitcoin considers the decree disproportionate. It turns crypto service providers into systematic collection points for sensitive information, then feeds an administrative exchange mechanism that can connect identities, home address, tax residence, crypto-asset activity and transfers.
The crypto specificity is central: when an identity is linked to an address, a transfer or a blockchain history, the exposure goes beyond the immediate tax need.
The legal challenge aims to suspend, delay, annul or amend the harmful effects of DAC8 and CARF wherever legitimate legal avenues exist. The French case is one front in that broader campaign.
What the case is not about
The case is not about placing crypto users outside tax law, nor about creating immunity from tax. Tax administrations already have targeted investigatory tools. The objection is to indiscriminate mass reporting of all users by default, especially where the data can expose holders to security risks beyond ordinary tax administration.
Bull Bitcoin’s position is that a tax administration can request information in a targeted, reasoned and proportionate way, without imposing automatic mass collection on all users.