The GENIUS Act Creates a New Attestation Role for CPAs. Here Is What the Stablecoin Reserve Examination Requirements Mean for the Accounting Profession.

The Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act was enacted in July 2025. On August 17, 2026, the U.S. Treasury released a Notice of Proposed Rulemaking to implement portions of it. The GENIUS Act is currently expected to take effect January 18, 2027, unless the statutory trigger tied to final implementing regulations causes it to take effect earlier. Under the Act, the effective date is the earlier of 18 months after enactment or 120 days after the primary federal payment stablecoin regulators issue final implementing regulations.

For most CPAs and accounting professionals, the GENIUS Act has not yet registered as something that directly affects their practice. That is about to change.

The statute contains a mandatory, recurring role for registered public accounting firms, one that does not require clients to hold cryptocurrency, invest in digital assets, or interact with blockchain at all. It requires accounting firms to perform monthly examinations of stablecoin reserve reports. Understanding what that means, what criteria apply, and what it will look like in practice is the preparation that matters right now.

What the GENIUS Act Actually Requires From Accounting Firms

The GENIUS Act establishes a regulatory framework for payment stablecoins, which are digital assets designed to maintain a stable value, typically by maintaining at least a one-to-one backing against high-quality liquid assets such as short-term U.S. Treasury securities.

Section 4 of the Act requires permitted payment stablecoin issuers to publish monthly reports on the composition of their reserves. Those reports must be examined by a registered public accounting firm each month. The CEO and CFO of the issuer must personally certify the accuracy of each monthly report to their primary regulator.

This is not a proposed requirement. It is a statutory requirement already in the law. The August 2026 Treasury NPRM addresses who may issue payment stablecoins and how issuance will be regulated. The monthly CPA examination obligation comes from the statute itself.

For issuers with more than $50 billion in outstanding stablecoin issuance that are not already subject to SEC public-company reporting requirements, the GENIUS Act also requires annual audited financial statements prepared in accordance with PCAOB standards.

What Examiners Will Actually Be Looking At

The examination covers reserve composition reports. These reports must demonstrate that the issuer holds permissible reserve assets in sufficient quantity to support full redemption of outstanding stablecoins. Permissible reserve assets under the statute include instruments such as short-term U.S. Treasuries, demand deposits at insured depository institutions, and central bank reserves.

The statute requires an examination of the monthly reserve composition report. An examination performed under applicable attestation standards and suitable criteria may involve testing management’s assertions about areas such as reserve composition, valuation, custody, and other characteristics addressed by the applicable criteria. The exact procedures should therefore be distinguished from the statutory requirement itself.

The AICPA has published its 2025 Criteria for Stablecoin Reporting, which covers two areas. Part I addresses 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. Part II, published in early 2026, addresses controls over stablecoin operations, including token lifecycle processes, reserve asset management, vendor oversight, and information technology.

According to the AICPA, its stablecoin reporting criteria meet the definition of “suitable criteria” for the examination engagements required under the GENIUS Act, and are designed for use by an independent CPA performing attestation engagements at a reasonable assurance level.

In its formal comments to regulators, the AICPA urged the OCC to explicitly specify that monthly reserve examinations be conducted using AICPA Attestation Standards. The AICPA also cautioned that limiting these engagements exclusively to PCAOB-registered firms could reduce CPA availability and create market bottlenecks for issuers, without improving quality where PCAOB inspection requirements do not already apply.

What Stablecoin Issuers Look Like as Clients

Stablecoins are no longer confined to crypto trading platforms. They are increasingly being evaluated and used for applications including payments, treasury activity, and digital asset settlement. For accounting professionals, that broader use makes the reserve structure and redemption mechanics behind payment stablecoins increasingly relevant.

As an explanatory analogy, reserve-focused assurance work for a stablecoin issuer can share certain practical questions with work involving other reserve-intensive financial structures, particularly whether sufficient eligible assets are held to support redemption obligations. This analogy does not mean that a payment stablecoin issuer is legally, regulatorily, or economically equivalent to a money market fund or an insured depository institution. The examination involves evaluating the composition, maturity profile, custody arrangements, and segregation of the reserve portfolio, and reporting on whether management’s assertions meet the applicable criteria.

The AICPA has stated that stablecoin issuers are already preparing monthly reserve reports using its criteria. This indicates that reserve reporting and related assurance practices are developing ahead of the GENIUS Act’s implementation. Accounting firms that develop fluency in stablecoin reserve structures and the applicable AICPA criteria will be prepared to serve that market when enforcement begins.

What CPAs Should Do Before the GENIUS Act Takes Effect

The most practical preparation involves two things: understanding the AICPA stablecoin reporting criteria and understanding stablecoin reserve structures well enough to evaluate management’s assertions about them.

The GENIUS Act mandates the examination. The AICPA has developed stablecoin reporting criteria that it says meet the definition of suitable criteria for these engagements, and it has urged regulators to expressly recognize examinations performed under AICPA Attestation Standards. The gap between the two is the technical knowledge required to apply one to the other, specifically, knowledge of how payment stablecoin reserves are structured, how issuers manage liquidity, and what constitutes appropriate controls over token lifecycle and reserve asset management.

That knowledge does not come from general audit training. It requires a foundation in how blockchain-based financial instruments work and how their unique characteristics affect traditional assurance engagements.

The Practice Opportunity Is Already Here

Monthly engagement frequency is unusual in accounting. Most attestation and assurance work runs on annual or quarterly cycles. Stablecoin reserve examinations under the GENIUS Act will require monthly deliverables, which changes the economics of the engagement and the operational requirements on the accounting firm.

Firms that are ready will have an advantage that compounds with each issuer they serve. Firms that are not will find themselves building that knowledge reactively, under time pressure, after the market has already formed.

The GENIUS Act is currently expected to take effect January 18, 2027, unless final implementing regulations trigger an earlier effective date under the statute. For accounting firms considering this emerging area of assurance work, the preparation window is already open.

Sources

• GENIUS Act | Guiding and Establishing National Innovation for U.S. Stablecoins Act, Pub. L. 119-27 | Enacted July 18, 2025
• U.S. Treasury | GENIUS Act Notice of Proposed Rulemaking | August 17, 2026
• AICPA | AICPA Urges OCC to Leverage Established Stablecoin Reporting and Controls Criteria in GENIUS Act Rulemaking | May 2026
• Journal of Accountancy | AICPA Urges Use of Its Stablecoin Criteria in GENIUS Act Rulemaking | May 5, 2026
• Thomson Reuters | Accounting Organizations Urge Banking Agencies to Specify AICPA Standards for Monthly Exam of Stablecoins | August 2026
• OCC | Notice of Proposed Rulemaking: GENIUS Act Requirements | February 2026