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Key facts (as of 29 October 2026)
- IFRS: classification depends on the holder's enforceable rights. A stablecoin carrying a substantive, enforceable right to redeem for cash can be a financial asset under IFRS 9; without that right it is generally an intangible asset under IAS 38, or inventory under IAS 2 if held for sale in the ordinary course of business (KPMG; ICAEW).
- US GAAP: the FASB proposed in August 2026 to add stablecoin examples to the cash-equivalents evaluation, covering on-demand redemption for cash, direct issuer redemption for known amounts and at least 1:1 segregated short-term reserves. Classification stays a policy election, and entities must consider the GENIUS Act's bar on treating payment stablecoins from non-permitted issuers as cash or cash equivalents. Comments are due 19 November 2026 (FASB, via Deloitte and Crowe).
- UK tax: ICAEW (November 2025) says stablecoins are not money for UK tax purposes and are generally chargeable assets, so a US dollar stablecoin held by a sterling taxpayer can produce gains or losses from FX movements. There is no HMRC guidance on whether one can be a debt.
- Reporting regimes: EU DAC8 and the OECD's Crypto-Asset Reporting Framework extend tax reporting to crypto service providers; check your obligations in each country.
Classification at a glance
| Framework | With enforceable direct redemption | Without | Notes |
|---|---|---|---|
| IFRS | Financial asset (IFRS 9); possibly cash equivalent (IAS 7) if value-change risk is insignificant | Intangible (IAS 38), or inventory (IAS 2) for traders | Same token can be classified differently depending on how it was obtained (ICAEW) |
| US GAAP | Proposed: may qualify as cash equivalent if criteria met; policy election | Other digital asset treatment | GENIUS Act restriction for non-permitted issuers |
NoteICAEW points out that a UK firm that holds USDC minted through Circle may have redemption rights, while one that bought the same USDC from an exchange may not, producing two classifications for one token. Document how each holding was acquired and what rights it carries.
The daily reconciliation routine
flowchart TD
A[Pull on-chain balances per wallet and chain] --> B[Pull custodian and exchange statements]
B --> C[Pull internal ledger: expected receipts and payouts]
C --> D{Differences?}
D -- None --> E[Sign off]
D -- Yes --> F[Classify: timing, fees, wrong network, unknown deposit]
F --> G[Investigate and journal]
G --> E| Check | Why |
|---|---|
| Balance per address per chain | USDT on Tron and on Ethereum are separate balances |
| Network fees | Paid in the native token (TRX, ETH, SOL), so track those balances too |
| Unidentified deposits | Screen before crediting; see Wallet screening |
| FX rate source | Use one documented source and time for valuations |
| Pending versus final | Book only on your finality policy; see Settlement finality |
Tax points
| Topic | What to check |
|---|---|
| UK corporation and capital gains | Stablecoins generally chargeable assets; FX moves can create gains (ICAEW) |
| Income received in stablecoins | Taxable as income when received; later disposal may create a gain (ICAEW) |
| VAT and sales taxes | Depends on the transaction and country |
| Reporting by providers | DAC8 in the EU, CARF elsewhere, Form 1099-DA in the US |
WarningThis is a fast-moving area and treatment varies by country. Get advice from accountants who know both your framework and digital assets.
Illustrative example: a month-end close
Illustrative example. The firm and figures are invented.
A UK PSP holds US$4m of USDC, all minted through a provider with a redemption agreement, and US$600,000 of USDT bought on an exchange for supplier payments. At month end it classifies the USDC as a financial asset under its IFRS policy and the USDT as an intangible asset, values both at its documented rate source, reconciles 14 wallets on three chains against its ledger, and finds one unidentified US$2,300 deposit, which it holds pending screening. Its tax adviser computes FX-driven gains on the USDT disposals in sterling.
Timeline
| Date | Event |
|---|---|
| June 2019 | IFRIC agenda decision on holdings of cryptocurrencies |
| 7 Nov 2025 | ICAEW article on stablecoin tax |
| 1 Jan 2026 | EU DAC8 applies |
| 18 Aug 2026 | FASB issues proposed ASU on cash equivalents and certain digital assets (Crowe) |
| 19 Aug 2026 | Deloitte summary of FASB proposal |
| 19 Nov 2026 | FASB comment deadline |
| 18 Jan 2027 | OCC GENIUS Act rule effective |
Q/A
Are stablecoins cash?
Not under IAS 7's definition of cash. Some may be cash equivalents in limited cases; the FASB proposal addresses US GAAP.
Do we pay tax on a stable token?
In the UK, a US dollar stablecoin can generate FX gains for a sterling taxpayer (ICAEW).
How often should we reconcile?
Daily for active wallets; more often for high-volume payout wallets.
What about network fees?
Book them as costs and reconcile native-token balances.
Sources
- Deloitte, Heads Up on FASB cash equivalents proposal (19 August 2026): https://dart.deloitte.com/USDART/home/publications/deloitte/heads-up/2026/fasb-proposes-enhancements-disclosures-cash-equivalents-clarifications-evaluation-certain-digital-as
- Crowe, FASB proposes cash equivalents guidance for stablecoins: https://www.crowe.com/insights/take-into-account/fasb-proposes-cash-equivalents-guidance-for-stablecoins
- FASB, project page: https://fasb.org/projects/current-projects/projects-history/cash-equivalents%E2%80%94disclosure-enhancement-and-evaluation-of-certain-digital-assets-423255
- KPMG, IFRS Q&A on stablecoins (2026): https://kpmg.com/xx/en/our-insights/ifrg/2026/qa-cryptoassets-stablecoins.html
- ICAEW, How are stablecoins taxed? (7 November 2025): https://www.icaew.com/insights/viewpoints-on-the-news/2025/nov-2025/how-are-stablecoins-taxed
- IFRS Interpretations Committee, holdings of cryptocurrencies (June 2019): https://www.ifrs.org/content/dam/ifrs/supporting-implementation/agenda-decisions/2019/holdings-of-cryptocurrencies-june-2019.pdf
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