The leading U.S. accounting body is making a bid to write the rules for the multi-billion dollar stablecoin industry, urging regulators to adopt its framework while warning against new restrictions that could limit the pool of auditors.
The American Institute of CPAs (AICPA) has formally asked the Office of the Comptroller of the Currency (OCC) to adopt its two-part stablecoin reporting criteria for implementing the 2025 GENIUS Act, aiming to set the standard for transparency and auditing in the U.S. stablecoin market.
"Trust and transparency are foundational to the success of payment stablecoins," Sue Coffey, the AICPA's CEO of public accounting, said in a statement Tuesday. "We believe these criteria offer the OCC a proven framework for implementing the GENIUS Act."
The proposal centers on the AICPA's "2025 Criteria for Stablecoin Reporting," which establishes standards for reporting on reserve assets and internal operational controls. Part one mandates disclosures on reserve composition and redemption risks, while part two, published in early 2026, addresses the controls governing token issuance and asset management.
The move positions the accounting profession to be the primary gatekeeper for stablecoin attestation but comes with a significant warning: the AICPA explicitly cautioned the OCC against limiting audit engagements to only Public Company Accounting Oversight Board (PCAOB) registered firms, arguing such a move could create costly bottlenecks for stablecoin issuers.
The AICPA's push leverages the fact that its criteria are not merely theoretical. In its comment letter, the organization noted that stablecoin issuers are already preparing monthly reserve reports in accordance with its framework, demonstrating what it calls market acceptance and practicality.
The body argues that its criteria already meet the definition of "suitable criteria" for the examination engagements required under the GENIUS Act, which was signed into law in 2025 to create a comprehensive regulatory framework for fiat-backed stablecoins. The AICPA is encouraging the OCC to explicitly recognize monthly reserve examinations and annual control examinations performed by independent CPAs under its existing attestation standards.
A key sticking point in the AICPA's letter is the potential for auditor limitation. The organization strongly advised against any rule that would exclusively mandate the use of PCAOB-registered firms for stablecoin examinations. Firms registered with the PCAOB are authorized to audit publicly traded companies, a higher and more complex standard that the AICPA argues is not necessary for this specific function.
According to the AICPA, such a restriction would significantly reduce the number of available CPA firms qualified to perform these examinations. This would likely lead to higher costs, create operational bottlenecks for issuers trying to comply with the law, and would not necessarily improve the quality of the attestations, especially in cases where PCAOB inspection does not apply.
"Independent, third-party assurance by CPAs has long been relied upon across regulated industries," Coffey added. "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 letter represents a decisive step by the accounting industry to embed its standards into the rapidly evolving digital asset landscape. By providing a ready-made, field-tested framework, the AICPA is aiming to accelerate regulatory compliance and assert the role of its members as the arbiters of trust for the growing stablecoin market, which now intersects with traditional finance and the U.S. Treasury.
This article is for informational purposes only and does not constitute investment advice.
