Why stablecoin controls create a solid foundation in an evolving environment

A new episode of the JofA podcast breaks down the AICPA’s updated criteria for stablecoin controls, explaining what issuers and practitioners need to know as regulatory expectations evolve.

This episode explores how revised AICPA stablecoin criteria support more consistent reporting, disclosure, and control assessments across a rapidly developing digital asset landscape.

Resources

Stablecoin reporting criteria

GENIUS Act summary of requirements

Stablecoin reporting and assurance

JofA news of the release of the criteria earlier this month

What you’ll learn from this episode:

• Why the AICPA developed updated criteria for stablecoin controls and how they complement existing presentation and disclosure criteria.
• How the criteria help issuers and auditors evaluate controls over tokens in circulation and the related reserve assets.
• How the guidance aligns with regulation, including federal guidelines in the GENIUS Act.
• Who can use the criteria and how practitioners can apply them in assurance engagements involving stablecoins.
• What work the AICPA Attestation Subgroup is planning for digital asset-related controls and auditing guidance.

Play the episode below or read the edited transcript:

— To comment on this episode or to suggest an idea for another episode, contact Neil Amato at Neil.Amato@aicpa-cima.com.

Transcript

Neil Amato: PwC partner Jeff Trent is my guest on this edition of the Journal of Accountancy podcast. I’m Neil Amato with the JofA. Thanks for listening.

Our topic is a recent AICPA stablecoin criteria update. Jeff, I’d like to quickly welcome you to the show and note that you’ve had several AICPA committee roles over the years. As a quick intro, can you tell the listeners about your role that relates to stablecoin reporting and the AICPA’s updated criteria related to stablecoins?

Jeff Trent: First off, thanks for having me today, Neil, and I appreciate being here. Certainly with respect to the stablecoin criteria, the AICPA has had a couple of different working groups and/or task forces, and I was part of the working group that established the criteria around stablecoin presentation and disclosure, which was issued last March. Then, I was fortunate enough to chair this most recent task force that was addressing the controls related to stablecoin issuance.

Amato: Great. We have covered the news of those criterias’ release in the Journal of Accountancy. We’ll share that link in the show notes for this episode, but we’re also going to expand a little bit on those in our discussion today. First, maybe for people who don’t know or need the refresher, what are these stablecoin controls criteria, and how do they relate to the previously published stablecoin presentation and disclosure criteria?

Trent: The criteria are a set of control objectives that the committee established to help stablecoin issuers address effectively the ongoing stablecoin operations with respect to tokens in circulation and the related reserve assets that underlie those stablecoins. In terms of how they relate, the previously issued criteria were presentation and disclosure criteria that really measure stablecoins in circulation and reserve assets at a point in time. And typically, given various regulations, that’s about every month you measure that.

To look at what it is that the company has in place to monitor and manage that that stays in balance, if you will, over time, we establish these controls criteria that allow the issuer and the auditor to measure the effectiveness of controls that underlie those stablecoin operations.

Amato: Thank you for that. Tell me a little more about why you think these are needed and why they are important to the overall stablecoin ecosystem?

Trent: Sure, happy to. When we looked at the existing regulatory guidance as we went into this process, there were some expectations from regulators with respect to controls in the stablecoin issuers’ operations. As we look at the overall ecosystem, we recognize that both in the stablecoin space as well as in the broader digital asset space, there are relationships between regulators, issuers, and users of services in the digital asset ecosystem that have evolving assurance needs, if you will.

Part of what that really comes down to is when we looked at existing regulatory guidance — let’s say, from the states that circa two or three years ago — and then evolving regulatory guidance with respect to what was in development from the federal government. And, an expectation of effective controls for a stablecoin issuer were part and parcel to what we were both seeing and hearing in those dialogues, and we felt that these criteria would address those needs, be they as they existed at the time or as they were revolving.

Amato: Obviously, this podcast is a show for our accounting audience, but who specifically can use these criteria?

Trent: The criteria are developed really to help issuers of stablecoins think about the controls they need in their operations to manage and maintain the stablecoin token in circulation and the related reserve assets. The criteria can then also be used by auditors of the issuer to issue opinions, and management makes an assertion against the criteria saying that they do have effective controls to meet those control objectives, and the auditor then issues an opinion on management’s assertion saying they hopefully agree that those controls were designed, implemented, and operating effectively over a period of time.

Amato: You’ve mentioned that these criteria aligned to regulations related to stablecoins. Were these criteria developed in response to the GENIUS Act? Could you say a little bit about what the GENIUS Act is?

Trent: Absolutely. They were not actually developed in response to the GENIUS Act. However, the work of our task force was fortunate in its timing insomuch as GENIUS was under development. We had the advantage of both knowing what was out there from the states as they currently existed and actually being at the forefront of engaging in the dialogue around the GENIUS Act. GENIUS, for listeners who may not know, is actually the federal guidelines that were published in the summer of 2025 around stablecoin issuers and specifically payment stablecoins, I should say.

They established a framework by which a stablecoin issuer can issue stablecoins in the U.S., and it has certain requirements around what the reserve must be comprised of and how much reserve must be in place. As I mentioned, while we didn’t develop this in response to that, the fact that we were working alongside its development and publication gave us some great insight both to have some influence with respect to how the GENIUS Act was being developed and then be responsive to it in the criteria as they were being published.

We feel very confident about that alignment, and we’re obviously staying close to the continued development of regulations that actually surround GENIUS.

Amato: Now that these criteria are published, and again, we’ll include a link in the show notes to them and our Journal of Accountancy news coverage. What’s next? Are there more projects that the AICPA Attestation Subgroup is working on?

Trent: Yeah, that’s a great question. A couple of things. One is with respect to the stablecoin criteria themselves, now that they are published, it’s a set of criteria, two different sets of criteria that were published together, but don’t necessarily have to be used hand in hand, although ideally they would be. We are working on technical Q&As for that release that would further assist practitioners and auditors in performing work around stablecoin issues. That’s currently underway and actually probably reaching mostly toward the end of that particular workstream as well.

But what we recognize is that as we were both wrapping up the stablecoin controls criteria and thinking more broadly about digital assets, is that our focus on controls was advantageous to the profession and that there continued to be some additional questions with respect to controls and digital assets. We have reconstituted the working group to now more broadly focus on controls in the digital asset ecosystem more broadly.

We just met for the first time very recently and are still working out exactly what the agenda of things that we will address will be. But we expect to help practitioners mostly in the auditing of digital assets, establishing helpful guidelines or whatever we can really come up with to help practitioners be more consistent in how they consider controls in the digital asset ecosystem.

Amato: This has been great. I think a quick-hitting and informative discussion on this topic. What about a closing thought or some takeaways for listeners as we finish this episode?

Trent: Yeah, Neil, I think the key takeaway for our listeners is that because GENIUS has now been published, there is a greater interest in stablecoins being issued across the U.S. We’ve both heard it and are starting to see it in our client basis as we’ve had various conversations. The great news for our listeners is whether you are an issuer or you’re a practitioner, the guidance around how to really meet the expectations of regulatory guidance really sits within these criteria.

As I mentioned, there’s alignment in terms of what we knew was out there. There was alignment with respect to what we understood was coming. If issuers and practitioners pick up these criteria and use them to help develop their own stablecoin controls or consider how to have conversations with their clients around stablecoin controls, and, for that matter, the reporting that they will need on a monthly basis with respect to presentation and disclosure, they’ve got really a guideline to do that in accordance with what people in the marketplace expect, especially the regulatory authorities.

Amato: I think that alignment and that kind of example, that framework are very important and some key takeaways that I got from the conversation. Jeff Trent, thank you very much for being on the JofA podcast.

Trent: Thanks, Neil, for your time. I appreciate it.