Form 3916-bis: every account, every year, no threshold

The scope

The duty covers digital-asset accounts opened, held, used or closed abroad during the year — one Form 3916-bis per account, filed with the income tax return. No value threshold, no activity condition: the dormant account is declared, the account closed in February too. What matters is the provider — its location outside France — not the logo: the same brand can host your account on a French or a foreign entity. Non-custodial wallets, where you alone hold the keys with no provider, are not "accounts" within the text — the dividing line runs, as in Madrid, through custody.

The price of forgetting

The fine is fixed: €750 per undeclared account and €125 per omission or inaccuracy, capped at €10,000 per return — raised to €1,500 and €250 where the account's value exceeded €50,000 at any moment of the year. Three forgotten platforms over three years is nine fines. And the heaviest effect is not the fine: undeclared foreign holdings stretch the administration's assessment window from three to ten years — every missing 3916-bis holds open years the statute would otherwise have closed.

Madrid asks for its form only above €50,000; Paris asks from the first euro — but doubles the fine past the same threshold. Two philosophies of the same information: the Spanish exception, the French inventory.

The match that is coming

Since 1 January 2026, EU platforms collect identities and volumes under DAC8; the first deliveries to administrations arrive in 2027. Matching then becomes mechanical: the list of accounts the providers report against the list of 3916-bis forms you filed. An account present on one side and absent on the other is the easiest flag in the entire system to automate — and the spontaneous route closes precisely when that match found you first.

What to do, by situation

1. Inventory once, properly. Every provider, each one's exact legal entity, closed accounts included — one afternoon that saves years.
2. File one 3916-bis per account, every year. Even with no disposals, even under €305 — the form's duty lives independently of the tax.
3. Missing past years: the spontaneous route first. File the omitted forms with an express note, before any letter — fixed fines negotiate better when the initiative is yours.
4. Document the custody of your wallets. What is non-custodial stays out of the form — provided you can show it.

The duty depends on facts this page does not know — custody, location, years concerned. It frames the rule; it does not apply it to your case, and reading it creates no professional relationship.