Comparative Regulatory Landscape

As stablecoins transition from experimental financial instruments to global settlement and collateral mechanisms, regulators across major jurisdictions are coalescing around a common set of supervisory priorities: validated reserve backing, clear custodial separation, and enforceable redemption pathways. These principles are now reflected in legislation, regulatory proposals, and supranational frameworks. The AICPA’s assurance model, while designed for application within the United States, has emerged as a reference architecture for stablecoin verification across borders. Its procedural alignment with key international standards positions it as a bridge between jurisdiction-specific compliance and globally consistent assurance.

European Union - MiCA Regulation

The European Union’s Markets in Crypto-Assets Regulation (MiCA), which entered phased implementation beginning in 2024, establishes a comprehensive legal framework for the regulation of crypto-assets, including stablecoin-like instruments formally referred to as asset-referenced tokens (ARTs). MiCA applies to both euro-denominated tokens and non-EU fiat–linked instruments circulating within the EU.

Under MiCA, ART issuers must:

• Undergo external reserve audits by qualified auditors, with updates at least quarterly. These reviews must confirm the existence, quality, and sufficiency of reserves supporting the circulating supply.
• Provide real-time reserve and redemption data to regulators and, where applicable, to the public. This includes access to reserve composition, token issuance history, and redemption throughput.
• Maintain legal clarity and enforceability of claims over reserve assets, which must be held in segregated accounts at EU-regulated financial institutions.

While the AICPA framework is not legally binding within the EU, it closely mirrors MiCA’s structural expectations regarding custody, operational integrity, and periodic attestation. U.S.-based stablecoin issuers with cross-border operations can utilize AICPA-aligned attestation procedures to satisfy MiCA-adjacent expectations, enabling dual-market interoperability without duplicative assurance regimes.

United States - Legislative Proposals in Congress

As of June 2025, several legislative proposals under review by the U.S. Senate call for the creation of a federal licensing framework for stablecoin issuers. These issuers would be chartered as limited-purpose financial institutions, subject to ongoing supervision, disclosure mandates, and prudential requirements.

Key features of these proposals include:

• Mandatory monthly attestation of reserve assets, conducted by licensed CPA firms, in accordance with defined assurance and audit protocols.
• Systemic oversight reporting, including redemption queue data, liquidity buffers, custodial structures, and stress testing results submitted to regulators.
• Regulatory jurisdiction under either the Office of the Comptroller of the Currency (OCC) or a newly constituted federal digital asset regulator, with the possibility of shared oversight with the Federal Reserve or Financial Stability Oversight Council (FSOC).

The AICPA assurance framework is already structured to accommodate these requirements. It specifies standardized procedures for reserve verification, segregation testing, and operational validation, providing an implementation-ready compliance mechanism that could be embedded directly into statutory mandates. Adoption of the framework would reduce interpretive ambiguity and promote alignment across U.S.-regulated issuers.

Financial Stability Board and BIS - Global Supervisory Convergence

At the international level, the Financial Stability Board (FSB) and the Bank for International Settlements (BIS) are spearheading efforts to extend global risk disclosure standards to crypto-assets and stablecoins with systemic implications. These efforts are grounded in the application of Basel III Pillar 3 principles, which emphasize transparency in risk exposures, liquidity conditions, and counterparty obligations.

Active supervisory developments include:

• Drafting of global audit and attestation expectations for crypto asset reserves held by regulated financial institutions, including banks offering custody or liquidity to stablecoin issuers. • Disclosure frameworks for redemption coverage ratios, collateral composition, and counterparty exposure metrics, which may become required under multilateral risk frameworks. • Introduction of harmonized attestation protocols to validate information disclosed in international regulatory filings, particularly for stablecoins used in payment systems or collateral chains.

While the AICPA framework is jurisdiction-specific, it codifies assurance procedures (such as reserve reconciliation, smart contract validation, and segregation verification) that are likely to be incorporated into globally coordinated standards. The framework serves as a template that regulators and standard setters in other jurisdictions can adapt or mirror, particularly in contexts where global coordination is necessary but statutory unification remains out of reach.

Cross-Jurisdictional Implications for Issuers

Stablecoin issuers operating across multiple regulatory environments will increasingly need assurance frameworks that are:

• Format-consistent, allowing the same attestation documentation to meet domestic and international requirements.
• Rigor-aligned, satisfying the procedural demands of multiple regulators without the need for separate audits or conflicting verification cycles.
• Transparently governed, providing clear delineation of responsibilities between issuers, custodians, and CPA firms across jurisdictions.

The convergence of U.S., EU, and international regulatory priorities around reserve validation, redemption enforceability, and assurance discipline signals a move toward formal recognition of third-party attestation as a prerequisite for legitimacy in the stablecoin sector. The AICPA framework (while emerging from a domestic professional body) is effectively positioning itself as a global tool for regulatory compliance, investor assurance, and financial integration.

Implications for Sovereign Risk and Monetary Integration

The development of independently attested stablecoins is transforming their relationship with sovereign monetary systems. As these digital instruments evolve from unverified payment tools into professionally assured financial assets, their eligibility for participation in national and cross-border monetary frameworks expands. When stablecoins operate under rigorous assurance structures (such as those defined by the AICPA) they become technically and institutionally compatible with official payment systems, interbank clearing layers, and central bank digital currency (CBDC) architectures. Conversely, stablecoins that lack professional verification may be viewed as threats to monetary sovereignty, financial stability, and macroeconomic control.

CBDC Interoperability and Attested Stablecoins

Central banks advancing CBDC initiatives (particularly those focused on cross-border settlement) require stable interfaces between sovereign digital currencies and third-party tokens. The Bank for International Settlements’ Project mBridge, involving multiple central banks in Asia and the Middle East, exemplifies efforts to create interoperable networks for wholesale CBDC settlement.

• Stablecoins backed by attested reserves and validated issuance controls can serve as technical bridges within these networks, facilitating the conversion of CBDCs into intermediary digital assets for remittance, trade finance, or liquidity provisioning.
• When reserve integrity and redemption mechanics are independently verified, these stablecoins may be approved as collateral assets, transaction intermediaries, or even as liquidity buffers in multi-currency CBDC environments.
• Without assurance, the risk of asset mismatches, delayed redemptions, or dual-claim conflicts increases, introducing potential instability into what are otherwise tightly controlled monetary systems. These risks are magnified in multi-jurisdictional CBDC pilots where trust in off-chain assets is crucial.

Assured stablecoins become tools for monetary system extension, rather than vectors of systemic uncertainty.

Cross-Border Settlement and Regulatory Parity

Cross-border stablecoin usage depends not only on technical integration but on regulatory recognition and procedural equivalence. When digital assets are used in settlement or collateral roles across jurisdictions, they must conform to shared expectations of solvency, legal clarity, and liquidity availability.

• The AICPA assurance framework offers a standardized procedural base that can be recognized across regulatory environments, even when legal regimes differ.
• Stablecoins that undergo attestation under the AICPA model can present auditable proof of reserve sufficiency, custodial segregation, and redemption performance, satisfying the core disclosure requirements of multiple financial authorities.
• This enables regulatory parity, allowing stablecoins to move between jurisdictions without incurring friction from capital treatment mismatches, disclosure barriers, or local registration requirements.

Rather than relying on bespoke bilateral agreements, assurance introduces a framework-based system of trust that facilitates scalable and efficient integration of tokenized assets into global monetary functions.

Mitigation of Shadow Currency Risk

Stablecoins issued outside formal financial systems, particularly in jurisdictions lacking enforceable regulatory oversight, have increasingly been described as “shadow currencies.” These instruments circulate alongside sovereign money, facilitating unmonitored capital flows, offshore asset accumulation, and regulatory arbitrage.

• In economies with currency controls or limited monetary policy tools, unregulated stablecoins can operate as synthetic substitutes for national currencies, bypassing domestic capital restrictions.
• The absence of independent reserve verification enables phantom liquidity, where tokens appear solvent but are under- or un-backed, introducing monetary leakage that can destabilize national financial systems.
• Implementing attested reserve assurance, even in partially regulated jurisdictions, reduces the credibility and uptake of unverified alternatives by elevating the transparency baseline across the sector.

Professionalized assurance acts as a systemic filter, differentiating between stablecoins that operate within financial guardrails and those that threaten to circumvent monetary governance altogether.

Shift From Policy Risk to Policy Alignment

The formalization of assurance practices signals a shift in how stablecoins are perceived by policymakers and regulators. Historically viewed as policy risks (unregulated instruments with the potential to undermine sovereign control) attested stablecoins are now increasingly framed as policy-aligned tools capable of supporting macroeconomic objectives and financial modernization.

• Stablecoins governed by attestation frameworks offer predictable monetary behavior, making them usable within sovereign monetary frameworks without compromising national authority.
• As central banks explore tokenized forms of public money, attested stablecoins can serve as complementary instruments, expanding the reach of fiat without diluting its credibility.
• Rather than displacing traditional monetary instruments, stablecoins with verified controls and reserve structures can be integrated as extensions of fiat architecture, governed through assurance and operational oversight.

This repositioning (grounded in transparency, validation, and institutional discipline) opens the door for structural integration; it enables central banks, supervisors, and public financial institutions to engage with stablecoins as interoperable, policy-compliant components of an evolving global financial system.