On 18 July 2025 the President of the United States signed the Guiding and Establishing National Innovation for U.S. Stablecoins Act — the GENIUS Act — into law. It is the first comprehensive US federal statute regulating payment stablecoins: digital assets designed to maintain a stable value relative to a fixed amount of money, typically the US dollar.
For finance professionals the law is significant not only because of its regulatory scope, but because it places reserve management, disclosure and independent examination at the centre of the stablecoin business model.
Who may issue payment stablecoins
The Act restricts issuance of payment stablecoins in the United States to permitted issuers, including subsidiaries of insured depository institutions, federally qualified non-bank issuers and state-qualified issuers that meet federal standards. Smaller issuers may opt for a state regime, while larger issuers come under federal oversight.
Reserves and monthly disclosure
Permitted issuers must maintain identifiable reserves backing outstanding stablecoins on at least a one-to-one basis. Eligible reserve assets are limited to high-quality, liquid items such as US currency, demand deposits, short-dated Treasury bills and certain repurchase agreements and money market funds.
Issuers must publish the composition of their reserves monthly, and those monthly reports must be examined by a registered public accounting firm. The CEO and CFO must certify the accuracy of the reports. Larger issuers are also subject to annual audited financial statements.
Accounting questions for holders and issuers
For companies that hold stablecoins, classification remains a matter of judgement under existing accounting standards. In the United States, ASU 2023-08 introduced fair value measurement for certain crypto assets, but its scope excludes assets that give the holder enforceable rights to underlying goods or services, which has led to debate about how stablecoins should be treated. Standard setters have been asked to consider whether further guidance is needed.
Under IFRS, the analysis depends on the rights attached to the token; holdings may fall under financial instruments or intangible assets standards, with very different measurement outcomes.
Implications for assurance
The requirement for accounting firms to examine monthly reserve reports creates a recurring assurance market. Practitioners will need to evaluate custody arrangements, the existence and valuation of reserve assets, and controls over token issuance and redemption. Audit committees of companies using stablecoins for treasury or payments should ensure controls over wallets, counterparties and reconciliations are well documented.
Conclusion
The GENIUS Act brings stablecoins closer to the regulated financial system. Its insistence on transparent reserves and independent examination shows that, even in digital finance, trust still depends on reliable reporting and assurance.
