The 2022 high-profile collapse of the algorithmic stablecoin TerraUSD and the subsequent moves toward government regulation saw a push to end stablecoin’s “wild west” era.
Stablecoin now enters a new era, thanks to the passing of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act in July 2025. The GENIUS Act marks the first comprehensive U.S. regulatory framework for stablecoin issuers and establishes rules to provide regulatory clarity and promote financial stability. Regulations include monthly examinations of stablecoin reserves performed by a registered public accounting firm.
The GENIUS Act provides a clear definition of stablecoin, a distinct regulatory framework, and guidelines for stablecoin issuers. CPAs have a role to play in protecting the public interest by providing assurance services. This alignment between legislation and professional oversight forms a powerful bond for enhancing transparency across the stablecoin landscape.
“Investors need that trust,” said Ami Beers, CPA, CGMA, senior director — Assurance and Advisory Innovation at AICPA. “And by having an attestation over the reserves every month, you’re giving investors at least a little bit more confidence they’ll have the ability to redeem those stablecoins.”
Regulatory clarity spurs stablecoin growth, transparency, and oversight
Stablecoins are a type of digital asset tied to a national currency or commodity, which provides more stability than other cryptocurrencies. Bitcoins, by comparison, are more volatile.
“The GENIUS Act now provides clear guidelines for stablecoins and the need for transparency in this space,” said Beers. “Because there are clear regulations, we will see large players enter this space.”
Bank of America announced shortly after passage of the GENIUS Act that, after initial hesitancy to launch a stablecoin, it will be moving off the sidelines and into the marketplace, thanks in part to the regulatory certainty provided by the act. JPMorgan Chase currently has a stablecoin-like digital token in development.
To remain compliant under the law, stablecoin issuers must publish detailed monthly reports that outline the total number of stablecoins both issued and in circulation, along with a comprehensive breakdown of the amount and composition of the reserve assets supporting them. The frequency of these reports does make the law unique and sets it apart from traditional financial reporting.
Assurance providers need to be ready for the increased need in their services. Beers cites the example of a company who makes stablecoin for another company — what are requirements of and risks for company No. 1? These organizations would be considered service organizations, and there will likely be a need for assurance over the systems and controls affecting the stablecoin issuer that would be addressed in a system and organization controls (SOC) report.
Stablecoin popularity will continue to grow, and our tools and resources will guide you as you offer stablecoin reporting and assurance services. Practitioners conducting examination engagements or stablecoin issuers can also use the 2025 Criteria for Stablecoin Reporting — a comprehensive framework that complements the requirements of the new legislation.
“This touches a lot on our different practitioners, whether they be in accounting, auditing, attestation, or SOC auditors,” said Beers. “I think [the law] has a lot of tentacles as we start to see more growth and launches of the uses of these different coins.”
Transparency and advocacy drive market legitimacy
Transparent reporting is a key component to establishing trust within the stablecoin market — and the GENIUS Act is a big first step in that direction. Two additional bills that passed in the U.S. House of Representatives in 2025 — the CLARITY Act and the Anti-CBDC Surveillance State Act — also work toward the goal of transforming the industry from the unregulated “wild west” to a more legitimate part of the global financial ecosystem.
Although the GENIUS Act itself is in effect, regulations from the Federal Reserve and the U.S. Treasury have yet to be released, making it essential to stay on top of updates, revisions, and professional development that affect how accountants perform attestation duties within the law.
“It’s really important to get educated and get an understanding,” said Beers.
“As other regulators put out their regulations, we’ll see engagement opportunities increase,” said Kate Kiley, Director — Congressional and Political Affairs at AICPA. “Knowing what the roadmap looks like will be useful to [the profession.]”
As the GENIUS Act goes into effect, areas will be revealed that need additional clarity and guidance. AICPA uses these moments to pursue meaningful change and advocate for improvements grounded in real-world experience. Other legislative developments on the radar of the AICPA Advocacy team include developments after the signing of H.R.1 (commonly referred to as OBBBA), or state-led proposals for sales taxes on professional services. For more updates like these and for legislative news, explore the efforts of AICPA Advocacy.