← Back to Research

FASB Proposes Cash-Equivalent Accounting for Stablecoins

A no-action letter lets Franklin's mutual funds and ETFs park cash in its $726 million tokenized money market fund, and sets the first template for blockchain-based fund ownership under the 1940 Act.

Clarification on the horizon: On August 18, the Financial Accounting Standards Board (FASB), which sets U.S. accounting standards, proposed guidance clarifying when certain stablecoins could meet the existing definition of cash equivalents. The proposal is open for public comment until November 19.

Why it matters: The clarification could remove a significant barrier to the use of stablecoins in corporate treasury, where blockchain-based infrastructure enables 24/7, near-instant transfers. To date, adoption has remained largely confined to the crypto firms and companies outside the U.S., partly because accounting treatment has been inconsistent across companies and auditors.

A test to pass: Under the proposed guidance, a stablecoin would need to meet three conditions to qualify as a cash equivalent:

  • A right to redemption on demand: The holder must be able to redeem the token for cash at its discretion, without significant fees or restrictions.

  • A direct redemption right with the issuer: The token must be redeemable directly from the issuer, not through an intermediary such as an exchange or market maker. Indirect redemption, the FASB argues, adds counterparty risk however liquid the secondary market is.

  • Segregated 1:1 reserves: Mirroring the GENIUS Act’s reserve requirement, the stablecoin must be backed at least 1:1 by short-term, highly liquid assets held in segregated reserves.

More consistent accounting: Stablecoins that pass the test could be treated as cash equivalents, narrowing the divergent practices seen today. It would also simplify reporting: companies that settle transactions in stablecoins without treating them as cash currently may need to track each payment separately and disclose the activity outside their cash flow statements.

  • No European equivalent: That relief would only apply to companies reporting under U.S. GAAP, the U.S. accounting standards. Under IFRS, the accounting framework used by listed companies in the EU and the UK, there is no comparable proposal. The International Accounting Standards Board (IASB) has issued no guidance on stablecoins, leaving classification to each company’s judgment. It is reviewing the definition of cash equivalents, but on general application questions, not stablecoins.

  • Nothing for bank ratios: Even in the U.S., the impact would stop at financial reporting, as the FASB does not set prudential rules. Cash-equivalent treatment would neither qualify a stablecoin for a bank’s liquidity buffer nor change its risk weighting. Under the Basel Committee’s crypto-asset rules, stablecoins on permissionless blockchains carry risk weights of up to 1,250%, with holdings capped at a small fraction of a bank’s capital. Although the Basel Committee has announced plans to revisit its crypto-asset capital rules, the current framework has officially been in effect since January 1, 2026.

The road ahead: For now, the guidance remains a proposal. Once the comment period closes on November 19, the FASB will resume its deliberations and could still amend or withdraw it. A final standard is unlikely before 2027.

Nik Fahrer is the Blockchain & Digital Assets Practice Leader at Forvis Mazars US, a leading audit and advisory firm.

In the short term, who would benefit first from this harmonization of accounting rules for stablecoins?

Initially, the main beneficiaries would be crypto-native companies that already hold significant stablecoin balances in their treasury operations.

For them, this Accounting Standards Update (ASU) may more closely reflect the way in which stablecoins are used in operations, while giving financial statement users a clearer picture of the company’s liquidity, business processes, and financial activity.

Today, a company can hold millions in stablecoins and still look short of cash on paper. That’s because the balances sit outside the official cash position that lenders and investors look at, and often they do not count toward the minimum amount of cash a company has promised its lenders to keep on hand. Treating stablecoins as cash equivalents would fix both.

This has a big knock-on effect. If stablecoins count toward that minimum, a company no longer needs to park extra traditional cash next to them just to stay within its loan terms. That frees up liquidity for other uses.

Traditional companies will take longer. Most still need to work through custody, governance, and the operational side of blockchain infrastructure first and also identify the right use cases.

Antoine Scalia is the founder of Cryptio, a financial accounting and reporting platform specializing in digital assets.

The FASB’s test also applies to the holder, not just the token. Two companies holding the same stablecoin might have to account for it differently. What does that mean in practice?

Exactly that. Even a stablecoin built to meet the GENIUS Act’s requirements, would not qualify automatically for every holder. What matters also is how a company can redeem. A company with an account at the issuer, and the right to redeem at par on demand, may treat the stablecoin as a cash equivalent. A company that has to sell through an exchange or market maker may not.

Moreover, access requirements vary across issuers. Circle Mint serves institutions operating at scale, Ripple limits direct RLUSD redemption to enterprise clients, and Paxos requires customers to complete its onboarding process to redeem PYUSD at par. A treasurer holding three different stablecoins would therefore need to maintain three separate issuer relationships.

One potential outcome is a two-tier market in which large institutions qualify for cash-equivalent treatment, while smaller holders of the same tokens do not. That gives issuers a new dimension to compete on: not yield or chains, but redemption eligibility and terms.

FASB clears the accounting barrier. Only a couple more left for corporate adoption.
Illustration: Blockstories