Your company wants to hold stablecoins: what rules should be in place before the first transaction?
A company considering holding stablecoins should not begin by choosing a wallet or buying its first token. The first decision is a governance decision: determine what the company authorises, within which limits, with which counterparties and under which procedures.
Several risks overlap: issuer risk, liquidity, custody, network risk, counterparty risk, wallet access, operational error, documentation and accounting treatment. An internal policy does not need to be long to be useful; it needs to provide unambiguous answers to the following questions.
1. For which purposes does the company authorise stablecoins?
The first control is to define permitted purposes: supplier payments, customer receipts, intragroup settlements, operational liquidity needs or temporary holdings. This prevents a tool introduced to facilitate an international payment from gradually becoming, without a formal decision, an investment vehicle or speculative asset. Each use should therefore be expressly authorised, limited or prohibited.
2. Which stablecoins may be held?
A company should not treat all stablecoins as interchangeable. The policy should establish eligibility criteria: the token’s legal nature, the identity and status of the issuer, reference currency, reserve transparency and composition, publication frequency, liquidity, supported networks and redemption terms.
Two checks should be kept distinct. The first concerns the stablecoin and its issuer: regulatory classification, rights attached to the token and redemption conditions. The second concerns the service providers used by the company: exchanges, custodians, conversion platforms or transfer providers. For companies operating in France or the EU, the relevant official national and European registers should be checked.
Market liquidity and redemption rights are not the same thing. A stablecoin may trade actively on a platform without the company necessarily having direct access to redemption with the issuer. The policy should therefore identify the actual exit mechanism: direct redemption, secondary-market sale, or a combination of both.
3. What exposure limits should be set?
A single overall limit may not be sufficient. A company can distinguish at least four levels: total stablecoin exposure, exposure per issuer, exposure per service provider or custody solution, and an operational limit per transaction. It may also set a maximum holding period and a minimum level of conventional bank liquidity.
These thresholds are not presented as general regulatory requirements. They are governance controls to be calibrated to the company’s business, exposure and risk tolerance.
4. Which networks and wallets are permitted?
Authorising a stablecoin does not mean authorising every representation of it or every network on which it circulates. The policy should identify accepted blockchains and specify conditions for using bridges, wallets and custody solutions. It should also define who may create an address, initiate a transaction and approve it.
5. Which service providers may the company use?
An exchange, custodian, wallet provider, conversion platform or transfer provider should not be selected solely on user experience or fees. The company should document the provider’s regulatory status, its exact role in the transaction flow, custody and withdrawal conditions, and its operational dependency on the provider.
6. Who may decide, execute and control?
The company should define an authority matrix. Segregation of duties should be proportionate to the company’s size, organisation and exposure. For significant transactions, the objective is to avoid initiation, approval, recording and control resting without safeguards on a single person.
Dual-approval thresholds, authorised personnel, access management and procedures for staff absence or departure should be defined before the first transaction.
7. What are the exit and redemption rules?
A treasury policy should govern exits as well as entries. It should identify situations requiring a reduction or closure of exposure: a limit breach, material depeg, suspension or difficulty of redemption, loss of liquidity, custody incident, significant network outage, regulatory change, or a major event affecting the issuer or a service provider.
The exit route should also be identified in advance: redemption with the issuer where the company actually has access, conversion through an authorised provider, or sale into a sufficiently liquid secondary market.
8. What information should be retained from the first transaction?
A blockchain transaction is not, by itself, a sufficient accounting trail. The company should be able to link the on-chain movement to its economic rationale: invoice or contract, counterparty, sending and receiving wallet, transaction hash, blockchain, date and time, quantity, fees, valuation used and service-provider evidence.
Before operations begin, the company should also define its reconciliation source of truth and how differences between blockchain records, provider interfaces, internal sub-ledgers and the general ledger will be handled. The purpose here is not to solve the entire reconciliation process, but to avoid inventing these rules at period-end.
French GAAP: a 2026 accounting change
For entities reporting under French GAAP, stablecoins that meet MiCA’s definition of electronic money tokens (EMTs) are recorded in account 513 on initial recognition under ANC Regulation No. 2026-01, approved by the Order of 12 August 2026. The regulation also introduces subaccounts for EMTs held, borrowed and lent. It applies to financial years beginning on or after 1 January 2027, with early application permitted for the financial year in progress on the date of publication in the French Official Journal.
9. How should the policy be monitored and reviewed?
The policy should not remain static. Periodic reviews should reassess approved assets, issuers, providers, networks, limits and incidents. Specific events can trigger an immediate review: a material depeg, suspension of redemption, custody incident, blockchain outage, regulatory change, deterioration in reserve transparency or a major event affecting a provider.
Before the first transaction: nine decisions, not simply a purchase
The question is therefore not merely: “Which stablecoin will we use?” Beforehand, the company should be able to answer nine questions: why use it, which one, within which limits, on which network, with which provider, under which authority matrix, how to exit, what evidence to retain and when to review the decision.
A stablecoin treasury policy therefore turns a sequence of technical transactions into a controllable financial process.
How BECTRA can help
BECTRA supports companies in designing and reviewing stablecoin treasury policies: approved assets and networks, exposure limits, wallet governance, counterparty criteria, control procedures and transaction documentation.
Comments