GENIUS Act leaves stablecoin accounting, risk gaps

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U.S. lawmakers nudged open the door to greater stablecoin adoption with a series of crypto- and digital asset-related acts last week — with President Donald Trump signing the GENIUS Act into law and the House of Representatives passing both the Digital Asset Market Clarity Act of 2025 or CLARITY Act, as well as the Anti-Central Bank Digital Currency Surveillance State Act, in votes Thursday and Friday.

While these three pieces of legislation represent a running start at providing structure to the previously murky stablecoin space, there are still questions left unanswered for finance chiefs weighing the risks and potential rewards of tapping such assets. CFOs also must carefully consider tax and accounting related rules, as well as how to hold and report such assets on their balance sheets, Nassim Eddequiouaq, CEO and co-founder of stablecoin issuance platform Bastion said.

“I think the one piece that is going to be important for CFOs is really monitoring everything around accounting rules,” Eddequiouaq told CFO Dive in an interview.

Opening the door

Stablecoins have crept further into CFOs’ sight lines throughout the year, as President Trump makes good on campaign promises to bring cryptocurrency firms more deeply into the mainstream. As such, a spotlight has been trained on the GENIUS Act as it moved through the U.S. Senate and House, with experts and industry players championing the purported regulatory clarity the act aims to bring to the space, CFO Dive previously reported.

Under the act, only “permitted issuers” are able to issue such coins for use by U.S. persons, according to a summary. Permitted issuers “must be a subsidiary of an insured depository institution, a federal-qualified nonbank payment stablecoin issuer, or a state-qualified payment stablecoin issuer,” according to the summary, and must be regulated by the “appropriate federal or state regulator.”

The clear guidelines provided by the act could provide a much-needed level of legitimacy to stablecoins for finance leaders, acting as the “green light” finance chiefs need for wider adoption, EY Global Blockchain Leader Paul Brody previously told CFO Dive.

Though public blockchains making use of such tokens have been available for many years, the lack of regulatory clarity surrounding their usage meant that “business users like CFOs have been reluctant to dive in,” Paul Brody, global blockchain leader for Big Four accounting firm Ernst & Young told CFO Dive in an emailed statement.

Story Continues“Now that the legislation is in place, I think we will see a huge acceleration in adoption by enterprises. The cost benefits of moving some payments to blockchain rails are substantial,” he said in the statement “Consumers already know this — they’re the ones already doing about $800 billion a month in stablecoin transactions Expect businesses to follow now that the path looks safe."

Peeking under the accounting hood

Still, CFOs, corporate treasurers and accounting leaders face lingering questions about what integrating stablecoins could mean for their business — and, critically for finance leaders, how those assets should be reported Among other terms, for example, the GENIUS Act establishes monthly reporting requirements for stablecoin issuers, including requiring an attestation engagement to be included in the reports.

Accounting standard setters and trade organizations have already taken stock of how the Act could shift reporting requirements, with some issuing their own criteria earlier in the year in advance of such legislation. The 2025 Criteria for Stablecoin Reporting guidance, first laid out by the the American Institute of CPAs in March, offers “a framework for issuers to present information on the outstanding stablecoins and the availability of the assets that back them,” Ami Beers, senior director, assurance and advisory innovation, AICPA told CFO Dive in an emailed statement. “We believe that these criteria can be used by issuers in preparing the monthly reports required by the Act.”

Among other things, the criteria can help issuers present information such as the number of tokens in circulation, the nature and amount of the reserve assets that back those tokens, and the comparison of tokens in circulation and reserve assets, Beers said “This information helps build trust by helping stakeholders understand what backs the tokens and how those amounts are verified and reported.”

Meanwhile, companies have begun to adopt the crypto-specific fair value accounting standards issued by the Financial Accounting Standards Board in 2023, which became effective December 2024.

The FASB declined to comment on the GENIUS Act. However, the board is currently in the midst of an agenda consultation, and “stakeholders have identified several standard-setting areas of interest, including potential projects related to stablecoins,” a spokesperson told CFO Dive in an email. “The Board will discuss all stakeholder feedback at a future meeting.”

Although the GENIUS Act lays out definitions for stablecoin issuance, the “next set of rules is probably going to be around accounting for U.S. companies: what is legal tender, what is not, what is treated as cash and cash equivalent, what is not,” Eddequioaq said. These are key questions today’s finance chiefs and corporate treasurers are considering, he said.

In considering stablecoins, CFOs and company leadership also need to keep a careful eye on what integrating such assets mean for their compliance and risk functions — the regulatory requirements for digital assets, their issuance and related factors differ from traditional such assets and therefore represent a new set of risks, Eddequiouaq said. At the end of the day, companies should be “focused on their core business,” he said. “Stablecoin is not their core business.”

“Stablecoins are just a tool,” he said. “They're going to disappear behind the scenes, and anything that helps make that more and more invisible, you should be working towards.”

Securities, revisited

As finance chiefs mull the potential impact of the GENIUS Act, they also need to ensure they are keeping a careful eye on the next round of stablecoin-related legislation, which is likely to play out over familiar stomping grounds — who will be responsible for regulating which assets, and which assets count as securities.

Under the terms of the GENIUS Act, payment stablecoins are not considered securities, eliminating in part historic contention between issuers and government regulators such as the Securities and Exchange Commission, which under previous SEC Chair Gary Gensler sued several such firms for violating securities law relating to the issuance of stablecoins.

The CLARITY Act aims to draw even firmer boundaries; under the proposed act, which has yet to pass the Senate, the bill seeks to create a framework for digital commodities — which it defines as “digital assets that rely upon a blockchain for their value,” and notes “The Commodity Futures Trading Commission must generally regulate digital commodities transactions,” according to a summary.

However, the legislation also “provides the SEC with jurisdiction over digital commodity activities and transaction engaged in by certain brokers and dealers on alternative trading systems and by national securities exchanges.”

“The GENIUS Act made it pretty clear that the issuer cannot, solely because a holder holds the stablecoin, distribute yield to that holder,” Eddequiouag said. “I'm hoping that the CLARITY Act helps define the line of what is acceptable versus not acceptable” regarding the legal relationship between coin holders and issuers, he said.

As the next round of stablecoin-related legislation circulates in the House and Senate, accounting organizations and standard setters are also keeping a close eye on how the budding industry takes shape.

“While the AICPA does not comment directly on pending legislation, we remain actively engaged in tracking policy and regulatory developments that may affect digital assets, including stablecoins,” Beers said in an emailed response to questions. He noted that the CLARITY Act includes “amendment language to the GENIUS Act that would require stablecoin issuers to establish and maintain internal controls over stablecoin operations and reserves as well as obtain an annual attestation report on the effectiveness of those controls

Because controls surrounding digital asset operations are an integral part of, and a foundation for, the reliability of information presented by stablecoin issuers, it is vital that those controls are implemented, operated, and monitored,” Beers said.

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