New York, NY (May 5, 2026) — The American Institute of CPAs (AICPA) has submitted a comment letter to the Office of the Comptroller of the Currency (OCC) encouraging regulators to leverage the AICPA’s recently published 2025 Criteria for Stablecoin Reporting in its rulemaking to strengthen transparency, accountability, and trust in the U.S. payment stablecoin market. The letter is in response to the OCC’s Advance Notice of Proposed Rulemaking under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).
“Trust and transparency are foundational to the success of payment stablecoins,” said Sue Coffey, CPA, CGMA, the AICPA’s CEO of Public Accounting. “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.”
To address growing demand for clarity and consistency in stablecoin reporting, the AICPA released the 2025 Criteria for Stablecoin Reporting 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.
Together, these two parts provide a comprehensive, decision‑useful framework that already aligns with and enhances the reporting, examination, and operational safeguards put forth by the GENIUS Act and the OCC’s proposal.
These criteria meet the definition of “suitable criteria” for the examination engagements required under the GENIUS Act and are specifically designed for use by an independent CPA performing attestation engagements at a reasonable assurance level.
Stablecoin issuers are already preparing monthly reserve reports in accordance with the AICPA criteria, demonstrating their practicality and market acceptance.
The AICPA 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 (SSAEs);
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 cautions that limiting these engagements exclusively to Public Company Accounting Oversight Board (PCAOB)‑registered firms could reduce CPA availability, increase costs, and create bottlenecks for issuers — without improving quality — particularly 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 also encourages the OCC to leverage existing stablecoin reporting criteria to minimize duplication and unintended complexity in final rules. The Stablecoin Presentation and Disclosure Criteria introduce additional transparency, such as clearer token reconciliation, reserve asset detail, and disclosure of events affecting redemption, without imposing unnecessary operational burden.
The letter further notes 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 said. “The AICPA stands ready to serve as a trusted resource to regulators as the stablecoin market evolves.”
About the American Institute of CPAs
The American Institute of CPAs (AICPA) is the world’s largest member association representing the CPA profession, with 397,000 members and a history of serving the public interest since 1887. AICPA members represent many areas of practice, including business and industry, public practice, government, education, and consulting. A founding member of the Association of International Certified Professional Accountants, the AICPA sets ethical standards for the profession, attestation standards, and U.S. auditing standards for private companies, not-for-profit organizations, and federal, state, and local governments. It develops and grades the Uniform CPA Examination, offers specialized credentials, partners across the profession to build future talent, and drives continuing education to advance the vitality, relevance, and quality of the profession.
Ranica Arrowsmith
Ranica.Arrowsmith@aicpa-cima.com
(212) 596-6117