The American Institute of CPAs asked the Office of the Comptroller of the Currency in a
President Trump
The AICPA noted that its
"Trust and transparency are foundational to the success of payment stablecoins," said Sue Coffey, the AICPA's CEO of public accounting, in a statement Tuesday. "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."
The AICPA's 2025 Criteria for Stablecoin Reporting comes in two parts:
- Presentation and Disclosure Criteria (Part I) establish 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.
- Controls Criteria (Part II) address controls over stablecoin operations, including token lifecycle processes, reserve asset management, vendor oversight and information technology.
The criteria meet the definition of "suitable criteria" for examination engagements required under the GENIUS Act and are specially designed for use by an independent CPA performing attestation engagements at a reasonable assurance level.
The AICPA pointed out that stablecoin issuers are already preparing monthly reserve reports in accordance with its criteria. It also said it supports the GENIUS Act's emphasis on independent assurance and encouraged the OCC to explicitly recognize:
- Monthly examinations over reserves performed in accordance with AICPA Attestation Standards;
- 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, however, that limiting such engagements exclusively to Public Company Accounting Oversight Board‑registered firms could reduce CPA availability, increase costs, and create bottlenecks for issuers — without improving quality — especially in cases 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."
The AICPA is also urging the OCC to leverage existing stablecoin reporting criteria to minimize duplication and unintended complexity in final rules. The Stablecoin Presentation and Disclosure Criteria add more transparency, such as clearer token reconciliation, reserve asset detail, and disclosure of events affecting redemption, without imposing unnecessary operational burden.
The AICPA pointed out that strong, independent external examination of internal controls provides more meaningful assurance to stakeholders than additional unaudited point‑in‑time reserve snapshots alone.
"CPAs bring more than a century of experience delivering trust and confidence in financial information," Coffey stated. "The AICPA stands ready to serve as a trusted resource to regulators as the stablecoin market evolves."
