Stablecoins under US GAAP: why classification starts with rights
A stablecoin targets a price close to one dollar. That feature alone does not determine its US accounting treatment. Does the holder own an intangible asset, a financial right or an asset that may be presented as a cash equivalent? The analysis starts with the rights obtained and the relevant accounting criteria.
ASC 350-60 does not automatically cover stablecoins
Established rule. The amendments communicated through ASU 2023-08 apply to fiscal years beginning after 15 December 2024. ASC 350-60 requires six cumulative scope conditions, including intangible-asset status, fungibility and no enforceable rights to underlying goods, services or other assets. In-scope assets are subsequently measured at fair value through earnings. [ASU23]
Interpretation requiring support. Where a stablecoin conveys such enforceable rights, its accounting cannot simply be inferred from the fair-value model for in-scope crypto-assets. The company must identify the model appropriate to the rights it actually holds.
BECTRA illustration — Distinguishing a custodian’s aggregate balance from client rights.
More than one accounting route may be relevant
The FASB staff’s 29 October 2025 discussion handout describes possible routes depending on contractual terms: intangible assets, financial assets, derivatives or cash equivalents. It recalls that cash equivalents are highly liquid, convertible to known cash amounts and exposed to insignificant interest-rate-related value changes. [FASB25]
The handout explains the issues under discussion; it is not itself a new accounting rule. A company needs to distinguish existing criteria from its judgment in applying them to its own facts.
The August 2026 proposal is not an adopted standard
Official proposal. On 18 August 2026, the FASB issued an exposure draft on cash equivalents, with comments due on 19 November. It proposes examples addressing direct on-demand redemption and segregated reserves, together with disclosures of significant cash-equivalent components. [ED26]
As reviewed on 22 October 2026, the document remains an exposure draft with comments due on 19 November. Its examples must not be treated as new requirements already in force.
BECTRA illustration — Distinguishing quantity, token parity and currency conversion.
The holder matters as much as the token
BECTRA analysis. Consider a fictional comparison: one company has direct contractual redemption access, while another holds the same token and relies entirely on selling through an exchange. Their rights and liquidity need separate analysis. The ticker cannot settle the question.
The useful question is therefore: what evidence supports the selected classification? An observed peg describes a price; it does not necessarily explain the legal route by which the holder can recover cash.
US subsidiary: build a classification file that can support close
A subsidiary preparing US GAAP reporting needs an approved classification memo linked to supporting records. The local controller and consolidation team should use the same contract version. A treatment adopted in the French parent’s accounts does not establish a US GAAP conclusion.
Holder — identify the legal entity that holds the wallet or account and the entity entitled to the contractual right being assessed.
Contracts — retain accepted terms, their dates, actual redemption access and restrictions. Marketing material does not replace these records.
Framework — explain the ASC 350-60 scope assessment and the selected model. Keep asset measurement separate from possible cash-equivalent presentation.
Reporting — reconcile the memo, ledger, treasury report and consolidation package. Document adjustments between accounting frameworks.
Reassessment — assign responsibility for reopening the analysis after contract, custody or holder-right changes. An unchanged ticker does not justify carrying a conclusion forward.
Worked case: two positions, two rights files
Fictional case. A US subsidiary tracks 600,000 units of one stablecoin: 400,000 in an account in its own name with the issuer and 200,000 with an intermediary. These quantities are reconciliation data, not a conclusion about dollar carrying amounts.
The controller opens two assessment lines. For the first, they verify account rights and limitations. For the second, they read the intermediary agreement before attributing a claim against the issuer to the subsidiary. They then reconcile 400,000 plus 200,000 to the position register. The case does not classify the first position as a cash equivalent or the second as an intangible: each requires a supported conclusion.
BECTRA can prepare the rights matrix, position reconciliation and an issues memo for discussion with accounting management and the auditor. The work makes evidence and judgments reviewable; it does not constitute an audit opinion.
Conclusion
US GAAP classification requires a distinction between ASC 350-60 scope, other applicable models and potential cash-equivalent presentation. The 2026 proposal helps explain the debate without replacing existing requirements.
Further reading
Sources
Official sources reviewed on 22 October 2026. File recommendations and the case are BECTRA analysis. The ASU communicates Codification amendments; the meeting handout and exposure draft are not newly effective standards.
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