French 1901 Association and Crypto: Practical Management Guide

Introduction: Associations in the Crypto Era

How to legally manage Bitcoin and crypto-assets within your association.

French 1901 law associations are increasingly interacting with the crypto ecosystem: receiving donations in Bitcoin, diversified treasury management, or providing legal structure for Web3 projects.

This practical guide supports association officers (presidents, treasurers, secretaries) in managing crypto-assets within their organization: legal, accounting, tax, and operational aspects.

Table of Contents

1. Why an Association Might Hold Crypto
2. Legal Framework
3. Practical Aspects
4. Accounting
5. Taxation
6. Receiving Crypto Donations
7. DAO Wrapper
8. Risks and Precautions
9. Templates and Models
10. FAQ

1. Why an Association Might Hold Crypto

Donations, diversified treasury, or DAO wrapper: multiple use cases.

1.1 Common Use Cases

1.2 Advantages of the Association Structure

1.3 Limitations to Consider

2. Legal Framework

No prohibition: associations can fully hold crypto-assets.

2.1 Legal Capacity

A French 1901 law association can hold any type of property, including crypto-assets:

"Declared associations may own and administer [...] the real estate strictly necessary for the accomplishment of the purpose they set out."

Source: Law of July 1, 1901, Article 6

Legal doctrine and practice extend this capacity to all movable property, including crypto-assets.

2.2 No Specific Prohibition

There is no legal text prohibiting an association from holding or using crypto-assets. The association operates within the general framework of contract and property law.

2.3 Need to Include in Bylaws

Recommendation: Explicitly include the possibility of holding crypto-assets in the bylaws or internal regulations.

Standard clause:

"The association may hold, acquire, and dispose of digital assets within the meaning of Article L.54-10-1 of the French Monetary and Financial Code, as part of its corporate purpose and financial management."

2.4 Required Decisions

3. Practical Aspects

Exchange account, wallets, and multisig: securing your digital assets.

3.1 Opening an Exchange Account

In the association's name:

Exchanges accepting associations:

• Coinhouse (France)
• Kraken (with complete documentation)
• Bitstamp (Europe)

3.2 Key Management

Who holds the access?

Recommendation: Multisig 2-of-3 with:

• President (key 1)
• Treasurer (key 2)
• Secretary or backup (key 3)

3.3 Asset Security

3.4 Security Procedures

Mandatory documentation:

• Inventory of wallets and addresses
• List of individuals with access
• Recovery procedure (backup seeds)
• Handover procedure in case of board changes

4. Accounting

Valuation at historical cost with provisions for depreciation.

4.1 Association Chart of Accounts

Crypto-assets must be recorded according to the association chart of accounts (ANC Regulation 2018-06):

Common recommendation: Account 50 or specific subdivision (508 "Other marketable securities").

4.2 Valuation

At entry (acquisition or donation):

• Acquisition cost (purchase)
• Market value on the day of receipt (donation)

At closing:

• Historical cost maintained
• Provision for depreciation if market value < cost

4.3 Standard Accounting Entries

Receiving a 1 BTC donation (value EUR50,000):

D 508 "Crypto-assets"              EUR50,000
    C 754 "Collections"                     EUR50,000
(Bitcoin donation received on DD/MM/YYYY, 1 BTC, rate = EUR50,000)

Purchase of 0.5 ETH for EUR1,500:

D 508 "Crypto-assets"               EUR1,500
    C 512 "Bank"                            EUR1,500
(Purchase of 0.5 ETH on Coinhouse, rate = EUR3,000/ETH)

Depreciation provision (BTC dropped from 50k to 40k):

D 686 "Provision expenses"          EUR10,000
    C 590 "Provisions on securities"        EUR10,000
(Depreciation provision for BTC, value at 12/31 = EUR40,000)

Crypto sale with capital gain:

D 512 "Bank"                        EUR60,000
    C 508 "Crypto-assets"                   EUR50,000
    C 764 "Securities income"               EUR10,000
(Sale of 1 BTC acquired at EUR50,000, sold for EUR60,000)

4.4 Financial Report

The annual financial report must include:

• The nature and amount of crypto-assets held
• The management policy adopted
• Realized gains or losses
• Provisions established

5. Taxation

Non-profit associations remain tax-exempt on their crypto-assets.

5.1 Non-Profit Association

A genuinely non-profit association is exempt from commercial taxes (corporate tax, VAT, local business tax).

Non-profit criteria:

• Disinterested management
• No competition with the commercial sector
• Operating conditions different from commercial

5.2 Impact of Crypto-Assets

5.3 Incidental For-Profit Activity

If the association has incidental for-profit activities:

• They may be exempt if < EUR78,596 (2025 threshold)
• OR ring-fenced in a separate account (corporate tax applies)

5.4 VAT

Crypto-asset transactions are generally VAT-exempt (CJEU Hedqvist ruling).

If the association is subject to VAT for other activities, crypto transactions do not qualify for input VAT deduction.

6. Receiving Crypto Donations

Accept Bitcoin and Ethereum to broaden your donor base.

6.1 Practical Arrangements

Display a donation address:

• Publish a Bitcoin/Ethereum address on the website
• Use a QR code
• Optional: Dedicated page with instructions

Donation page example:

DONATE IN CRYPTO

Bitcoin (BTC): bc1q...xyz
Ethereum (ETH): 0xABC...123

Your donations help us pursue our mission.
For a tax receipt, contact us with your transaction details.

6.2 Convert or Hold?

6.3 Tax Receipt: On What Basis?

For RUP (Recognized as Public Interest) or public interest associations:

The donor may benefit from a tax reduction (66% income tax or 60% corporate tax).

Example:

• Donation: 0.5 BTC on March 15, 2025
• Rate on March 15: EUR80,000/BTC
• Donation value: EUR40,000
• Tax receipt: EUR40,000

6.4 Donor Obligations

The donor must:

• Value their donation at the day's rate
• Declare the "disposal" (taxable event)
• Potentially pay capital gains tax (if purchase price < donation value)

Warning: Donating crypto generates a taxable capital gain for the donor if the value has increased since purchase.

7. DAO Wrapper

The association can serve as a legal interface for a decentralized organization.

7.1 Principle

An association can serve as a legal "wrapper" for a DAO:

+-------------------------------------+
|     French 1901 Association         |
|   (legal personality, contracts)    |
|                                     |
|      +---------------------+        |
|      |        DAO          |        |
|      | (smart contracts,   |        |
|      |  on-chain           |        |
|      |  governance)        |        |
|      +---------------------+        |
|                                     |
+-------------------------------------+

7.2 Governance Articulation

7.3 Standard Bylaws

Corporate purpose:

"The association's purpose is to [project mission], notably through the development, promotion, and governance of the [name] protocol, in coordination with decentralized governance exercised by the community via on-chain mechanisms."

Governance:

"The Bureau commits to executing decisions adopted by the community via the on-chain governance process, in compliance with the law, the bylaws, and the association's interests."

7.4 Existing Examples

8. Risks and Precautions

Volatility, lost keys, and liability: managing risks effectively.

8.1 Identified Risks

8.2 Insurance

Officer liability insurance:

• Covers management errors
• Verify inclusion of digital assets

Asset insurance:

• Few products available
• Coverage via regulated exchange (Coinhouse)

8.3 Transparency

Toward members:

• Information at general assembly on crypto-assets
• Amounts, policy, results

Toward authorities:

• Declaration if requested
• Sincere accounting

8.4 Handover

In case of board change, plan for:

• Access transfer procedure
• Training for new officers
• Up-to-date documentation

9. Templates and Models

Ready-to-use bylaw clauses and minutes templates.

9.1 Bylaw Clause

ARTICLE X - FINANCIAL MANAGEMENT AND DIGITAL ASSETS

The association may hold, acquire, dispose of, and use digital assets,
including crypto-assets within the meaning of Article L.54-10-1 of the
French Monetary and Financial Code (Bitcoin, Ethereum, stablecoins, etc.).

Management of these assets is entrusted to the Bureau, which defines
the holding, security, and usage policy, in compliance with the corporate
purpose and the association's interests.

A report on digital assets held is presented at each annual General
Assembly meeting.

9.2 Internal Regulations (Excerpt)

SECTION Y - CRYPTO-ASSET MANAGEMENT

1. HOLDING POLICY
The association may hold crypto-assets up to a limit of [X]%
of its total reserves.

2. AUTHORIZED ASSETS
- Bitcoin (BTC)
- Ethereum (ETH)
- Regulated stablecoins (USDC, EURC)

3. SECURITY
Assets valued over EUR5,000 must be stored on a multisig 2-of-3
device, with:
- Key 1: President
- Key 2: Treasurer
- Key 3: [Secretary / Secure backup]

4. DECISIONS
- Acquisition < EUR1,000: Treasurer alone
- Acquisition EUR1,000 - EUR10,000: Bureau approval
- Acquisition > EUR10,000: General Assembly or Board vote

5. DOCUMENTATION
A crypto-asset register is maintained and updated with:
- Nature and quantity of assets
- Holding addresses
- Dates and amounts of transactions

9.3 Standard Minutes Template

MINUTES OF BUREAU MEETING
Association [NAME]
Date: [DATE]

AGENDA
1. Authorization to hold crypto-assets
2. Definition of management policy

DECISIONS

1. The Bureau, after deliberation, authorizes the association to:
   - Open an account on the Coinhouse platform
   - Hold crypto-assets (BTC, ETH, stablecoins)
   - Up to a limit of EUR20,000 in value

2. Management is entrusted to the Treasurer, under the President's oversight.

3. A report will be presented at the next General Assembly.

President: [Signature]
Treasurer: [Signature]
Secretary: [Signature]

10. FAQ

Q1: Can an association legally hold Bitcoin?

Yes, without any doubt. There is no prohibition. The association must simply ensure that holding crypto is compatible with its corporate purpose and provide for the terms in its internal documents.

Q2: Do the bylaws need to be amended to hold crypto-assets?

Not mandatory, but recommended. An explicit clause secures the practice and informs members. Otherwise, a Bureau or General Assembly decision may suffice.

Q3: How to account for an airdrop received?

As exceptional income. Value at the rate on the day of receipt and record:

D 508 "Crypto-assets"           X EUR
    C 778 "Exceptional income"        X EUR

Q4: Can the association do staking?

Yes, with caution. Staking income should be recorded as financial income. Be mindful of the risk of for-profit reclassification if amounts are significant.

Q5: Can donors receive a tax receipt for a crypto donation?

Yes, if the association is authorized (RUP, public interest). The receipt states the value in euros on the day of donation. The donor must declare this "disposal" themselves (potential capital gain).

Q6: Who is liable in case of loss of crypto-assets?

Officers may be liable in case of management error (negligence, lack of security measures). Hence the importance of documented procedures and officer liability insurance.

Q7: Does the association need to declare its crypto-assets somewhere?

No specific declaration, but crypto-assets must appear in the annual accounts and the financial report presented at the General Assembly.

Q8: Can association workers be paid in crypto?

Yes, it is possible. Euro valuation remains necessary for accounting and any social/tax obligations of the recipient.

Conclusion

Key Points

Treasurer's Checklist

• Verify compatibility with bylaws
• Vote an authorization (Bureau or General Assembly)
• Open an exchange account in the association's name
• Set up multisig if > EUR5,000
• Document procedures and access
• Properly record all transactions
• Inform members (annual report)

Related Articles — DAO & Legal Structures

• DAO Legal Status in France
• Share Tokenization in France
• ICO IDO France Regulation

Sources

• Law of July 1, 1901, on the Association Contract
• ANC Regulation 2018-06 (association chart of accounts)
• BOFiP: Taxation of associations

Article written in December 2025