FASB Adds Project on Stablecoins to Technical Agenda (October 31, 2025)

Further, during its October 29, 2025, meeting, the Board considered the feedback related to topic (1) above. At that meeting, the Board decided to add to its technical agenda a project on clarifying whether certain digital assets may be classified as cash equivalents1 and discussed stakeholder feedback received as part of staff outreach on the topic.

The Board also provided feedback to the FASB staff on the following possible approaches2 to a project addressing the potential classification of certain stablecoins as cash and cash equivalents:

The Board did not reach any conclusions about these alternatives during the meeting but shared views with the FASB staff on potential further considerations related to these alternatives as well as additional feedback on the project. As discussed during the meeting, the project may include consideration of topics such as which additional attributes would be associated with a stablecoin that may be classified as a cash equivalent, regulatory developments associated with the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, and additional disclosures that may be appropriate.

 

Connecting the Dots

On July 18, 2025, President Trump signed into law the GENIUS Act, which establishes the first comprehensive federal rules for stablecoins and defines a payment stablecoin, in part as follows:

(A) . . . [A] digital asset —

(i) that is, or is designed to be, used as a means of payment or settlement; and

(ii) the issuer of which —

(I) is obligated to convert, redeem, or repurchase for a fixed amount of monetary value, not including a digital asset denominated in a fixed amount of monetary value; and

(II) represents that such issuer will maintain, or create the reasonable expectation that it will maintain, a stable value relative to the value of a fixed amount of monetary value; and

(B) [that is] not . . . —

(i) . . . a national currency; (ii) . . . a deposit . . . ; or (iii) . . . a security.

The GENIUS Act does not become effective until the earlier of 18 months after enactment (January 2027) or 120 days after the date on which the primary federal payment stablecoin regulators issue any final implementation regulations. Various agencies have rulemaking responsibilities under the GENIUS Act. The U.S. Department of the Treasury is responsible for issuing regulations, and several other agencies (i.e., the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency) are required to adopt regulations implementing GENIUS Act provisions. Once the Act becomes effective, only permitted payment stablecoin issuers may issue payment stablecoins in the United States. Notably, the Act makes it illegal to treat “a payment stablecoin that is not issued by a permitted payment stablecoin issuer . . . as cash or as a cash equivalent for accounting purposes.” For more information about the GENIUS Act, see Deloitte’s publication 2025 — The Year of Payment Stablecoins: The GENIUS Act Is Law, Now What?