AICPA urges use of its stablecoin criteria in GENIUS Act rulemaking

The AICPA submitted a comment letter encouraging the Office of the Comptroller of the Currency (OCC) to incorporate AICPA stablecoin criteria into rulemaking under the GENIUS Act to improve transparency, accountability, and trust in the payment stablecoin market.

The comment letter is in response to the OCC’s Advance Notice of Proposed Rulemaking under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, P.L. 119-27, legislation that establishes assurance and attestation requirements, creating opportunities for CPAs.

The AICPA’s 2025 Criteria for Stablecoin Reporting: Specific to Asset-Backed Fiat-Pegged Tokens already aligns with and enhances the reporting, examination, and operational safeguards put forth by the GENIUS Act and the OCC’s proposal, according to an AICPA news release.

“Trust and transparency are foundational to the success of payment stablecoins,” Sue Coffey, CPA, CGMA, the AICPA’s CEO–Public Accounting, said in the news release. “The AICPA’s stablecoin criteria were developed through a rigorous, public process led by the accounting profession and are already being used. The criteria will continue to serve as the basis for issuers reporting as well as by independent CPAs in examination engagements. We believe these criteria offer the OCC a proven framework for implementing the GENIUS Act.”

Part I of the AICPA’s stablecoin reporting criteria establishes consistent reporting on stablecoins outstanding and the assets backing them, including disclosures on token population, reserve composition, redemption terms, custody arrangements, and risks affecting redeemability. Part II, published in early 2026, addresses controls over stablecoin operations, including token lifecycle processes, reserve asset management, vendor oversight, and information technology.

The criteria, according to the news release, meet the definition of “suitable criteria” for the examination engagements required under the GENIUS Act, enacted in July 2025, and are specifically designed for use by an independent CPA performing attestation engagements at a reasonable assurance level.

Stablecoin issuers are already preparing monthly reserve reports in accordance with the AICPA criteria, the news release said, demonstrating their practicality and market acceptance.

The AICPA supports the GENIUS Act’s emphasis on independent assurance and encouraged the OCC to explicitly recognize:

• Monthly examinations over reserves performed in accordance with the AICPA Statements on Standards for Attestation Engagements;
• Annual independent examinations of controls supporting stablecoin operations, using the AICPA Stablecoin Controls Criteria; and
• The critical role of independent CPAs in good standing, subject to professional ethics, peer review, and state licensure oversight.

The AICPA cautioned that limiting these engagements exclusively to PCAOB-registered firms could reduce CPA availability, increase costs, and create bottlenecks for issuers — without improving quality — particularly where PCAOB inspection does not apply.

“Independent, third-party assurance by CPAs has long been relied upon across regulated industries,” Coffey said. “The same professional standards, independence requirements, and peer review processes that safeguard public trust today are well suited to supporting confidence in stablecoin reserves and operations.”

— To comment on this article or to suggest an idea for another article, contact Bryan Strickland at Bryan.Strickland@aicpa-cima.com.