Response to the ACPR-AMF Fintech Consultation on Smart Contracts

In February 2025, we actively participated in the ACPR-AMF Fintech Forum’s consultation on the certification of smart contracts. Our response highlights the need for a pragmatic certification framework that fosters innovation. Recognizing the rapid evolution and interconnected nature of smart contracts, particularly in decentralized finance (DeFi), we advocate for a voluntary or ex post certification approach, rather than an ex ante requirement that could stifle innovation.

We emphasize that community best practices and widely recognized security standards—such as the Ethereum Enterprise Alliance’s EthTrust, the OWASP Top 10, and open vulnerability registries—effectively address many security risks. Furthermore, we emphasize the importance of adopting clear and transparent governance processes as well as detailed documentation to build user trust and understanding.

We caution against overly rigid regulatory approaches and suggest a proportionate and flexible certification model tailored to the criticality and complexity of individual contracts or protocols. Given the global nature of decentralized finance, we emphasize the importance of international harmonization to avoid regulatory fragmentation that could undermine competitiveness and innovation in blockchain technologies in Europe.

Finally, recognizing the potential burden that certification processes could place on small projects, we propose establishing targeted incentives or legal safeguards to support innovation and prevent regulatory arbitrage.

Through this contribution, we remain committed to developing a balanced approach that secures smart contracts, supports innovation, and strengthens Europe’s leadership in decentralized finance and blockchain technologies.