Corporate Treasury and Stablecoins: Accounting, Banks and Risk in 2026

The treasurer of a mid-sized freight forwarder in Rotterdam gets a simple question from her CFO: a Brazilian customer wants to pay $2 million in USDC, so can they just hold it for a few weeks until the next supplier run? The operational answer takes ten minutes. The accounting answer, until very recently, took a technical memo, a call with the auditor and a shrug. Is a dollar stablecoin cash, an investment, or something else? On 18 August 2026 the US Financial Accounting Standards Board published a proposal that finally starts to answer, and it turns on details most treasury teams have never had to think about.

Why treasurers suddenly care

For most companies, stablecoins arrive from the outside: a customer wants to pay in them, a marketplace settles in them, or a subsidiary in a dollar-short market has been receiving them informally. The scale of the instrument makes it hard to ignore. Total stablecoin supply was about $306 billion as of October 2026, and genuine stablecoin payments reached roughly $390 billion in 2025, according to McKinsey and Artemis estimates.

Corporate use is still early. In an EY-Parthenon survey of 350 firms conducted in June 2025, 9% of corporates and 23% of financial institutions said they used stablecoins. Only 8% of corporates accepted them as payment. Among current users, 41% reported savings of at least 10%, mostly on dollar cross-border B2B payments. The striking number for treasury is a different one: 79% of corporates converted stablecoins to fiat immediately after a transaction. Companies are using stablecoins as a rail, not yet as a place to keep money.

The reason is not mysterious. Regulatory uncertainty was the top concern at 73%, with accounting and tax treatment second at 38%. If you cannot tell your board whether an asset counts as cash, you do not hold it overnight.

The accounting gap: ASU 2023-08 does not cover most stablecoins

US GAAP got its first crypto-specific standard in December 2023, ASU 2023-08, which requires qualifying crypto assets to be measured at fair value through net income. That fixed the old problem of bitcoin being carried as an impaired intangible. It did not fix stablecoins.

The standard's scope has six criteria, one of which is that the token must not give the holder enforceable rights to underlying goods, services or other assets. As Indiana University's Vivian Fang explained in Bloomberg Tax in October 2025, reserve-backed redemption rights are exactly such a claim, so many stablecoins fall outside ASU 2023-08. Falling outside does not make them cash. Companies have instead had to apply other guidance, and practice has varied.

The cash-equivalent test in ASC 230 asks for short-term, highly liquid investments readily convertible to known amounts of cash and so near maturity that rate risk is insignificant. A stablecoin has no maturity date at all, which is why auditors have hesitated.

FASB's August 2026 proposal: three attributes

FASB added a digital assets project to its agenda in 2025, after the GENIUS Act became law in July of that year, and on 18 August 2026 it issued a proposed update to Topic 230. Deloitte's Heads Up summary sets out what it does and does not do. The definition of a cash equivalent would not change. Instead, FASB adds illustrative examples built around three attributes, considered together:

1. An on-demand contractual right to redeem for cash at the holder's election, without significant fees.
2. A direct redemption right against the issuer, rather than having to rely on an exchange or market maker to get known amounts of cash.
3. Segregated reserves of short-term, highly liquid assets held at least one-for-one against tokens in circulation.

Classification would be a policy election, not a requirement. A token backed by crypto assets or gold fails, per one of the proposal's cases. And every entity presenting cash equivalents would have to disclose the significant components each year, whether those are Treasury bills, money market funds or stablecoins. Comments are due by 19 November 2026; the effective date is not yet set, and early adoption would be permitted.

The proposal makes the relationship with the issuer, not the token, the thing auditors will test.

The second attribute is the one that will catch companies out. A business that receives USDC from a customer and holds it in a self-custodied wallet, with no account at the issuer, may not have a direct redemption right at all. To get dollars it must sell through an exchange or OTC desk. Under the proposal's logic, the same token could be a cash equivalent in one company's books and not in another's.

And under IFRS?

International standards have no stablecoin-specific guidance. The IFRS Interpretations Committee concluded in 2019 that cryptocurrency holdings are not cash and generally fall under intangible assets or inventory. A May 2026 IASB staff paper on intangible assets notes strong stakeholder support for better treatment of crypto, with cryptoassets added to the list of potential projects, but no decisions and no timetable for a stablecoin answer. Groups reporting under IFRS should expect to wait longer than US filers. A qualified accountant should confirm the treatment for any specific holding.

The GENIUS Act draws a line around issuers

The GENIUS Act, signed in July 2025, creates the federal framework for payment stablecoins: licensed issuers, one-for-one reserves in cash and short-term Treasuries, monthly reserve reports, no interest paid to holders and priority claims for holders in an issuer's insolvency. For treasury, its most important feature is the one Deloitte flags: once effective, the Act generally prohibits treating a payment stablecoin from a non-permitted issuer as cash or a cash equivalent. It takes effect at the earlier of 18 months after enactment or 120 days after final implementing rules, which puts the outside date in January 2027.

That gives treasurers a clean policy rule: approved issuers are permitted issuers, full stop. It also means the largest stablecoin by supply, USDT at about $184 billion, sits in a different category for US-reporting companies unless its issuer's US arrangements change. Our pieces on GENIUS and MiCA and GENIUS Act implementation follow the rule-writing.

Banking access: better, still uneven

Holding stablecoins is useless if your bank will not touch the fiat leg. On 7 March 2025 the OCC issued Interpretive Letter 1183, confirming that national banks may provide crypto custody, hold deposits that back stablecoins and engage in certain stablecoin payment activities without first seeking supervisory non-objection, as Sullivan & Cromwell summarised. At the time the FDIC and Federal Reserve had not matched it, so what a bank will do still depends partly on its regulator.

In practice, a treasury that wants to hold stablecoins needs three things lined up: a bank that will receive wires from the issuer or an exchange without freezing them for review, a custodian or wallet setup that internal audit will sign off, and ideally a direct issuer account so that redemption at par does not depend on a third party. Many companies still route through a specialist payments partner instead. EY's survey found 56% of corporates prefer embedded APIs in existing treasury platforms and 70% would be more inclined to adopt with ERP integration.

Risk policy: what March 2023 taught

The case every treasury committee should study is the weekend Silicon Valley Bank failed. Circle disclosed that $3.3 billion of USDC reserves, nearly 8% of about $40 billion, sat at SVB; USDC fell below 87 cents on secondary markets, CNBC reported, before recovering once US authorities backstopped SVB depositors. A token can be fully reserved and still trade well below par when its reserves are temporarily inaccessible. Our history of depegs covers the other episodes.

A sensible stablecoin treasury policy borrows from money market fund policy and adds crypto-specific controls:

• Approved issuers only, tied to legal status (GENIUS-permitted or MiCA-authorised) and published reserve reports.
• Concentration limits per issuer and a maximum share of operating liquidity in stablecoins.
• Holding-period caps, for example a rule that receipts are converted within a set number of business days unless a payment out is scheduled.
• Custody standards: multi-approval wallets, whitelisted addresses and segregation of duties, covered in our guide to self-custody and custodial wallets.
• Chain and contract risk: which blockchains are approved, and how sanctioned-address screening is done.
• Redemption drills: periodically redeem a small amount to prove the route works.

Worked example: the $2 million USDC receipt

Return to Rotterdam. The figures for yield and spread below are illustrative assumptions, not market quotes. The company receives 2,000,000 USDC and needs the dollars in 21 days.

• Hold as USDC. No yield, since GENIUS-compliant issuers cannot pay holders interest. If the company had instead parked $2 million in a money market fund at an assumed 4% annual yield, it would have earned about $4,600 over 21 days ($2,000,000 x 4% x 21/365). That is the opportunity cost.
• Tail risk. In a repeat of March 2023, a 13% secondary-market discount would show a temporary mark of about $260,000 if the company had to sell that weekend. With a direct issuer redemption account, it could wait for par; without one, it is exposed to the market price.
• Convert immediately. If an OTC desk or payments partner converts at an assumed all-in 0.10%, the cost is $2,000. The company then holds dollars in a bank account it already understands.

Unless the company expects to pay suppliers in USDC within days, converting is usually cheaper and simpler, which is exactly what most corporates in the EY sample did. The calculation changes for firms paying stablecoin-accepting suppliers, where holding avoids two conversions. Firms should take advice from their auditor and a qualified adviser before setting policy.

What to watch next

• 19 November 2026: comment deadline on FASB's Topic 230 proposal. Watch whether the direct-redemption attribute is softened for holders using regulated intermediaries.
• By 18 January 2027: the latest date the GENIUS Act takes effect, if final rules are not finished sooner, bringing the bar on non-permitted issuers into force for cash classification.
• Bank regulators: whether the FDIC and Federal Reserve align with the OCC on stablecoin activities, which would widen corporate banking access.
• Tokenised deposits: bank-issued alternatives, discussed in our comparison of stablecoins, CBDCs and tokenised deposits, may give treasurers on-chain dollars that are already deposits on the balance sheet.

The shift in 2026 is that the stablecoin question has moved from "is this allowed?" to "is this cash?". For treasurers, the answer will depend less on the token than on the paperwork behind it: who issued it, under which law, and whether the company can walk up to the issuer and get its dollars back.

About this researchMuffinPay InsightsIndependent analysis of stablecoins, CBDCs, cross-border payments and digital public infrastructure. Every figure is linked to its source. Read our editorial standards →