France’s Council of State has rejected an emergency request from crypto companies Bull Bitcoin and Paymium to temporarily suspend the country’s implementation of the European Union’s DAC8 crypto tax reporting rules.
The decision does not end the broader legal dispute. Bull Bitcoin’s separate case seeking the complete annulment of the French DAC8 decree remains active before the court.
The companies had argued that the reporting framework could create serious security risks by centralizing sensitive information about cryptocurrency users, including their identities and transaction activity.
French court finds no urgent reason to suspend DAC8
Bull Bitcoin said the emergency suspension request was filed in August 2026 alongside an earlier legal challenge targeting the decree itself.
The suspension case was designed to stop the DAC8 rules from being applied while the Council of State considered the broader annulment challenge.
However, the court ruled that Bull Bitcoin and Paymium had not demonstrated enough urgency to justify temporarily freezing the decree.
According to an excerpt of the ruling shared by Bull Bitcoin, the court said that a potential risk with a very low probability was not enough to establish an urgent situation.
The companies had argued that centralized databases containing information about crypto holders could become attractive targets for hackers and criminals.
Data collected under the reporting system can include personal identification details as well as information related to crypto transactions.
Bull Bitcoin warned that if such information were leaked, criminals could potentially use it to identify cryptocurrency holders and their families for extortion, kidnapping or other physical attacks.
Bull Bitcoin disputes court’s assessment
Bull Bitcoin disagreed with the court’s conclusion about the level of risk.
The company pointed to comments reportedly made by France’s General Directorate of Public Finances during parliamentary discussions in February.
According to Bull Bitcoin, French tax authorities had previously acknowledged that a broad reporting system for crypto portfolios could centralize sensitive information such as investor identities and the value of their holdings.
The company argued that such information could become particularly valuable to hackers.
Bull Bitcoin also emphasized that the emergency ruling only addressed whether the situation was urgent enough to justify suspending the decree.
It did not settle the legal arguments contained in the company’s main challenge.
The company said the rejection of the emergency request should therefore not be interpreted as the Council of State rejecting its broader arguments against the DAC8 implementation.
Bull Bitcoin viewed the absence of a substantive ruling on those arguments positively, although that remains the company’s interpretation. The Council of State has not yet ruled on the merits of the annulment case.
Crypto-related physical attacks raise security concerns in France
The dispute comes at a time when France has experienced a noticeable increase in physical attacks involving cryptocurrency holders and their relatives.
By early July 2026, France had recorded 77 crypto-related incidents involving kidnapping, unlawful detention, extortion or attempted offenses, according to Interior Minister Laurent Nuñez.
That compares with 45 cases reported during 2025.
Authorities had arrested around 200 people in connection with attacks or preventive operations and introduced additional measures aimed at protecting people considered at risk.
These measures included improved intelligence sharing and faster identification systems for crypto industry participants facing potential threats.
Blockchain security company CertiK separately reported 52 verified physical crypto attacks worldwide during the first half of 2026.
According to its data, France accounted for 33 of those incidents.
CertiK estimated total financial exposure linked to the cases at approximately $124.1 million, including stolen crypto, ransom demands, frozen assets and other financial losses.
Personal data may increase risks for crypto holders
Chainalysis also documented dozens of physical crypto attacks globally during the first half of the year.
The analytics firm identified compromised personal information as one potential factor behind the high number of incidents in France.
It cited allegations involving stolen tax records containing information about investors.
However, Chainalysis did not establish a direct connection between any specific data breach and individual crypto-related attacks.
Physical incidents have continued in France.
In August, a couple in Rion-des-Landes was reportedly kidnapped in an alleged crypto extortion attempt in which attackers sought access to Bitcoin and other digital assets.
Two suspects were later arrested.
Another couple in Alès was reportedly tied up and threatened by armed intruders who demanded cryptocurrency transfers.
The attackers remained inside the home for more than two hours before fleeing when police arrived.
These incidents have added to concerns about how sensitive information related to crypto ownership should be collected and protected.
DAC8 expands crypto reporting across Europe
DAC8 came into effect across the European Union on January 1, 2026.
The rules expand the EU’s automatic tax information exchange framework to include cryptocurrency and other digital assets.
Under the system, reporting crypto asset service providers must collect information about certain transactions carried out by customers who are residents of EU member states.
Information that may need to be collected includes customer names, addresses, tax identification numbers, dates of birth and tax residence information.
The framework covers several types of activity, including crypto-to-fiat transactions, exchanges between cryptocurrencies and certain transfers.
Withdrawals to self-custody wallets can also fall within the reporting framework when the transaction involves a regulated reporting service provider.
Crypto companies are currently collecting information covering transactions made during the 2026 calendar year.
The first reporting and automatic exchange of that data is scheduled for 2027.
France faces a major crypto tax reporting challenge
The DAC8 framework is expected to give European tax authorities significantly more visibility into cryptocurrency activity.
Chainalysis estimated that France generated approximately $9.4 billion in potentially taxable crypto activity during 2025 across six blockchains included in its analysis.
The estimate included about $1.7 billion in crypto income, $2.5 billion in realized gains and $5.2 billion in payments.
However, Chainalysis described those figures as potentially taxable activity.
It did not suggest that the entire $9.4 billion represented unpaid taxes or government revenue.
French taxpayers separately reported approximately €368 million in cryptocurrency gains for the 2024 tax year through around 24,000 filings.
The two figures cover different periods and categories of activity, meaning they should not be directly compared.
Bull Bitcoin continues legal challenge against DAC8 decree
Bull Bitcoin said its original case seeking the complete annulment of the French DAC8 decree remains before the Council of State.
The company said the case questions whether the French government had sufficient authority to implement the measure and also raises concerns relating to fundamental rights and European privacy protections.
Following the rejection of its emergency request, Bull Bitcoin said it intends to publish legal filings, supporting documents and arguments connected to the suspension proceeding.
The wider legal challenge will now determine whether the French implementation of DAC8 can remain in place.
For the time being, the reporting rules continue to apply.
Under the current timetable, crypto asset service providers must report information covering the 2026 calendar year by September 30, 2027.
That information will then be automatically exchanged between tax authorities across participating EU jurisdictions.
The Council of State has not yet issued a final ruling on Bull Bitcoin’s request to annul the French DAC8 decree.
