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Jeff Trent

Partner, PwC US

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If your company issues or might soon issue stablecoins, a new day for reporting and trust-building has arrived. The American Institute of CPAs (AICPA) has issued holistic criteria for stablecoin reserve reporting. It also plans to release for public comment, proposals for stablecoin-related controls.

A turning point in stablecoin reporting is here: 4 takeaways for issuers

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4 minute read

June 11, 2025

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Jeff Trent

Partner, PwC US

If your company issues or might soon issue stablecoins, a new day for reporting and trust-building has arrived. The American Institute of CPAs (AICPA) has issued holistic criteria for stablecoin reserve reporting. It also plans to release for public comment, proposals for stablecoin-related controls.

Together, these documents provide a common framework to allow issuers to meet current and proposed regulatory expectations. They also provide a basis for consistent, verifiable reporting that can build trust in your stablecoins among customers and other key stakeholders. As these criteria and controls become the industry standard, public acceptance of the broader stablecoin ecosystem will likely grow too.

As a member of the AICPA committee that crafted this new framework, I’d like to share some of the most important takeaways for issuers.

Stablecoins’ nature makes this new framework necessary

Stablecoins are a type of digital asset whose value is pegged to another asset like the US dollar or gold. This promised stability is what makes stablecoins appealing. More and more companies have been looking to them as a source of opportunities in the digital asset landscape.

But how can stakeholders be confident that issuers hold enough core assets so that, if the need arose, stablecoin holders really could exchange them at the promised rate?

Traditional financial institutions build trust with stakeholders through regulatory compliance and transparent, standardized reporting. That hasn’t been the case for stablecoins, which have faced a patchwork of regulations with no holistic, common reporting framework.

Proof of Reserves Reports aren’t enough

In theory, a Proof of Reserves Report—a document issued by an independent third party to demonstrate the assets that back up a given stablecoin—should allow stakeholders to assess issuers’ reserves. But these reports have lacked consistency as to what they cover and how they back up their statements. There’s also been no common framework to understand and assess these reports. And Proof of Reserves Reports have usually not been built to meet current or proposed state and federal regulations. 

The new AICPA criteria are different. My fellow committee members and I designed them around existing state regulations and assessed them against proposed state and federal ones.

We also built the criteria to provide a consistent framework to understand stablecoin reports, to help stakeholders assess them.

No matter what US state you’re in, regulations are coming

While the federal government works to create a regulatory framework for stablecoins, regulations and guidelines already exist in some states. New York’s stablecoin regulations, for instance, are among the most rigorous — but the proposed federal regulation is similarly rigorous, as are the regulations that more and more states are preparing. Nearly all (including the legislation currently before Congress) contain an expectation of auditor examinations.

Even if you are in a state with few or no stablecoin-specific regulations, new state and federal rules will likely soon require you to comply with stricter regulations already adopted in places like New York.

AICPA's framework offers transparency and trust

AICPA’s 2025 Criteria for Stablecoin Reporting provides guidelines for transparent, comparable and consistent reporting. It also offers a transparent framework to understand and assess reports. Once the public comment period is over, AICPA will finalize its Proposed Criteria for Controls Supporting Token Operations: Specific to Asset-Backed Fiat-Pegged Tokens. That will complete the framework for stablecoin reporting.

As PwC’s representative, I worked with other audit firms, academics and other private sector representatives to draft both documents. We sought and received input from both regulators and stablecoin issuers.

I anticipate that stablecoin issuers who follow AICPA’s framework will likely be well positioned to meet existing and evolving federal and state regulations.

By fostering transparency in your stablecoin reporting, this framework can also build trust among your other key stakeholders, including customers.

We’re at a turning point for stablecoins

Stablecoin issuers now have at their disposal what many digital asset players have long sought: A clear framework to help consistent and strong reporting and enhance transparency and stakeholder trust. As this framework becomes the industry standard, the broader public’s trust in stablecoins may grow as well.

This framework may then prove to have been a turning point — the moment when stablecoins began to be not just a niche asset, but a trusted foundation of the global financial system.

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