Legal Action
Bull Bitcoin's legal action before the Conseil d'État
The challenge filed against the French DAC8 transposition decree and why it matters.
Updated
On 24 February 2026, Bull Bitcoin filed a summary petition (requête sommaire) before the French Conseil d’État against Decree No. 2025-1276 of 19 December 2025, the main French transposition measure for DAC8.
This action is only a beginning. It is part of a broader strategy to suspend, delay, annul or amend the harmful effects of DAC8 and CARF by every legitimate legal means available. It matters beyond France, because DAC8 is part of a broader global architecture for crypto tax reporting.
Short answer
On 24 February 2026, Bull Bitcoin filed a summary petition (requête sommaire) before the Conseil d’État to annul Decree No. 2025-1276 of 19 December 2025, the main French transposition measure for DAC8. It is the first step of a broader strategy to suspend, delay, annul or amend the harmful effects of DAC8 and CARF by every legitimate means.
A mémoire ampliatif will follow to develop the legal grounds. The Conseil d’État may rule on the merits within 12 to 24 months depending on the procedure.
Key facts
| Question | Answer |
|---|---|
| Petition filed | Summary petition (requête sommaire), 24 February 2026 |
| Court | Conseil d’État (France) |
| Challenged text | Decree No. 2025-1276 of 19 December 2025 |
| EU framework | DAC8 (and CARF at the global level) |
| Claimant | Bull Bitcoin |
| Immediate goal | Annulment of the challenged decree |
| Next step | Mémoire ampliatif (to come) |
| Timeline | Ruling on the merits possible within 12 to 24 months |
| Overall strategy | Suspend, delay, annul or amend the effects of DAC8 and CARF |
The main legal grounds
The reference file identifies three lines of argument:
- Over-transposition and abuse of power (excès de pouvoir) : the decree would extend the obligations beyond the necessary scope.
- Procedural irregularity : the procedure by which the decree was adopted is contested.
- Disproportionate infringement of fundamental rights : the automated collection of exhaustive financial data infringes privacy and data protection.
Why the action is strategic
The litigation is not only about a technical text. It seeks recognition that the French transposition of DAC8 cannot ignore the specific nature of crypto-assets, the transparency of public blockchains and the physical risk borne by holders and their relatives.
A victory would create a useful precedent for other member states and for the discussions around CARF. The stakes go beyond France, because DAC8 is part of a broader global architecture for crypto tax reporting.
Procedure timeline
The summary petition opens the litigation. A mémoire ampliatif then develops the legal grounds; it is still to come. The Conseil d’État rules on the merits on a timeline that can extend over 12 to 24 months depending on the procedure.
What the action seeks
The immediate goal is the annulment of the challenged French decree. The broader goal is to establish a precedent on the proportionality of mechanisms for the automatic, mass exchange of crypto data.
Bull Bitcoin wants to open an institutional dialogue on an alternative compatible with taxation, security and fundamental rights.