BSPCE & AGA Explained: France's Startup Equity Tax Rules 2026

BSPCE (bons de souscription de parts de créateur d'entreprise) are the near-universal early-employee equity grant at eligible French startups, structurally an option: you pay an exercise price to acquire shares, then owe tax on the gain. AGA (attribution gratuite d'actions) are France's equivalent of an RSU grant, common at later-stage companies: shares vest and are simply granted, no exercise price paid, but you're taxed on their full value at vesting. Classic options sur titres have fallen out of use, BSPCE's tax treatment dominates it for any company that qualifies.

It sets the tax rate on your entire exercise gain. If you'd already worked at the company for 3+ years on the date the BSPCE was granted, the exercise gain is taxed at a flat 12.8% income tax (or you can opt into barème progressif) plus 18.6% social levies, 31.4% combined. Under 3 years at grant, the rate jumps to 30% income tax plus the same 18.6% social levies, 48.6% combined. On a €90,000 exercise gain, that's the difference between owing €28,260 and owing €43,740, a genuinely large gap driven entirely by a tenure test at a single fixed date.

The grant date, and this trips people up because it's fixed at the moment the BSPCE was awarded, not when you eventually choose to exercise. Someone who joined a company, received a BSPCE grant in their first year, then exercised it 5 years later is judged on their tenure at the original grant date, under 3 years in that scenario, so the higher 30% rate applies even though 5 years have since passed. Vesting schedules and exercise timing don't change the rate; only your tenure on the specific grant date does.

AGA has no exercise price and no exercise event, tax is triggered at vesting (acquisition) on the full value of the shares received. The first €300,000 of acquisition gain per beneficiary per year gets a 50% abattement (so only half is added to taxable income and run through barème progressif), any amount above €300,000 is taxed as ordinary salary with no reduction. On top of the income tax, the full acquisition gain (no abattement) is also subject to 18.6% social levies and a 10% contribution salariale spécifique, both AGA-only charges BSPCE doesn't have.

The subsequent sale (cession) is a separate tax event from exercise/vesting, taxed at the standard PFU flat rate of 31.4% (12.8% income tax + 18.6% social) on the gain between sale price and the value already taxed at exercise/vesting. This applies identically to both BSPCE and AGA, it's ordinary plus-value-de-cession-de-valeurs-mobilières treatment, not instrument-specific.

The PEA/PEA-PME tax wrapper can, in some structures, shelter cession gains from tax entirely if the shares are held inside one, a genuinely significant planning lever this calculator doesn't model. Beyond that, BSPCE's 3-year tenure test is itself the main lever within your control: an employee weighing exercise timing close to their 3-year anniversary has real reason to wait, the tax-rate difference is large enough to matter, not just a marginal optimization.

BSPCE specifically requires the issuing company to meet eligibility conditions (broadly: unlisted, under 15 years old, not majority-owned by another company, French or EU-headquartered), which is why it's described as a startup instrument, not a general equity mechanism. AGA has broader eligibility and is more commonly seen at larger, later-stage companies that no longer qualify for BSPCE. If you're unsure which instrument your own grant is, check your grant letter, the tax treatment is materially different between the two.