Stablecoins with a CASP: which documents explain the client’s rights?

7 hours ago

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An account with a European provider may display stablecoins without a dedicated on-chain address for each client. Finance teams need to understand the client’s rights behind the account balance.

A custody framework exists

Established rule. MiCA Article 75 addresses client custody, including agreements and position records. These provider obligations do not themselves determine the client’s accounting classification.

BECTRA illustration — Assessing rights before choosing an accounting classification.

Different documents answer different questions

BECTRA analysis. The contract explains rights and return conditions. The individual statement identifies the position allocated to the business. Relevant blockchain data helps explain movements and addresses.

None is a perfect substitute for the others. A named statement alone does not establish the assets’ legal treatment on provider failure. An omnibus address cannot automatically allocate its full balance among clients.

An apparent difference

Suppose the custodian’s public wallet holds more tokens than the company’s statement. That is not necessarily an error: the wallet may include several clients. First establish what each source represents.

Question to establish. Verify the provider’s actual status, covered service and applicable terms for the precise contracting entity rather than relying on its commercial brand.

BECTRA illustration — Transfer restrictions require a separate assessment of rights and measurement.

Include current supervisory developments

Supervisory position. On 8 October 2026, ESMA set out expectations for services involving non-MiCA-compliant stablecoins. Corporate users should assess service continuity and exit conditions. This is not a new accounting-classification rule.

Conclusion

Evidence of holding depends on consistency between the contract, client records and relevant movements. Regulation provides reference points; assessment of the actual position remains necessary.