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Key facts (as of 29 October 2026)
- Market concentration: about US$302bn of dollar-pegged stablecoins were in circulation on 29 October 2026. USDT (about US$181bn) and USDC (about US$71bn) make up more than 80% (DefiLlama).
- Redemption cost differs by issuer. In private.law's example, redeeming US$5m with Tether costs the greater of US$1,000 or 0.1%, which is US$5,000, plus a one-off US$150 verification fee. Redeeming against Circle's EU issuer costs nothing, because MiCA forbids the fee. Rotating the position four times a year makes the difference about US$20,000.
- Interest ban. None of the main regimes allows issuers to pay holders interest. Holding US$5m in tokens for 12 months gives up roughly US$200,000 at a 4% money-market rate (private.law).
- Thin euro market. EURC was about €485m in circulation on 29 October 2026 (DefiLlama). All euro-pegged tokens tracked by DefiLlama total about €0.8bn on the same date. private.law's lower figure of roughly €500m for all euro stablecoins appears to be dated.
- Depeg history. USDC fell below US$0.87 in March 2023 when US$3.3bn of its reserves was stuck at Silicon Valley Bank (CNBC).
Choosing the token
| Need | Typical choice | Caveat (private.law) |
|---|---|---|
| Dollar settlement from an EU or UK entity | USDC | The MiCA Article 23 cap applies to dollar tokens used for payments in the EU |
| Euro leg | EURC or EURCV | Thin market |
| Counterparties on exchanges and OTC desks that use USDT | USDT | Issuer outside MiCA and US federal status; redemption fees apply |
| US-regulated counterparties from 2027 | Permitted issuers' tokens | Offering ban for non-permitted tokens from July 2028 |
| HKD, JPY or SGD leg | Licensed local coins (HKDAP, JPYC, XSGD) | Access limits and caps, e.g. ¥1m per transfer in Japan |
Counterparties often dictate the token. Check what your PSPs, payout partners and exchanges accept and on which network. See USDT vs USDC vs PYUSD vs EURC and Choosing a chain.
Treasury flow
flowchart LR
IN[Inbound: PSP settlement, client payments] --> SCR[Screen and reconcile]
SCR --> OPS[Operating wallet: hours of payouts]
OPS --> PAY[Payouts and prefunding]
SCR --> BUF[Buffer: next settlement window]
BUF --> OPS
SCR --> CONV[Convert surplus to fiat]
CONV --> BANK[Bank accounts, two or more providers]
BANK --> MMF[Yield instruments where policy allows]Hold the token for settlement, not as savings
Because of the interest ban, a stablecoin balance earns nothing. private.law notes that treasuries therefore hold the token across settlement windows, not as a store of value. Yield-bearing alternatives such as money-market funds and tokenised deposits are different instruments with their own legal forms. See Tokenised deposits vs stablecoins.
Policy limits
A written treasury policy should set at least:
| Limit | Example wording |
|---|---|
| Maximum stablecoin balance | No more than X days of expected payouts |
| Maximum per issuer | No more than Y% of stablecoin holdings with one issuer |
| Maximum per custodian or venue | No more than Z% at one provider |
| Approved tokens and chains | List, reviewed quarterly |
| Conversion trigger | Convert above the cap within one business day |
| Depeg trigger | Stop accepting and review if a token trades outside a set band |
Risk checklist
| Risk | Control |
|---|---|
| Depeg or issuer failure | Diversify issuers; set exposure limits; know each issuer's redemption terms |
| Banking-partner failure | Keep at least two settlement accounts with different providers licensed in different countries (Finzil) |
| Network outage or congestion | Support more than one network for key flows |
| Freezes | Issuers can freeze addresses; screen counterparties first |
| Regulatory change | Track token status in each market (for example, MiCA delistings) |
| Operational error | Address allow-lists; test transfers; multi-approval |
Warning"Fully backed" does not mean "risk-free". In March 2023 USDC's reserves existed and were disclosed, yet part sat in a failing bank. Parity returned only after federal authorities decided to support SVB depositors (private.law).
NoteReconcile daily. On-chain balances, ramp balances, bank balances and the ledger should match, with a documented source of funds for every movement. See Accounting, reconciliation and tax.
Illustrative example: a broker's treasury
Illustrative example. The broker and figures are invented.
A broker receives about US$3m a week in stablecoins from a PSP and pays out US$2m a week to clients and affiliates. Its policy caps stablecoin holdings at five days of payouts, about US$1.4m, split no more than 70/30 between USDC and USDT, because some counterparties only take USDT. Surplus converts to fiat daily at two banks in different countries. Redemption is through a licensed provider, not directly with issuers, so it compares the provider's spread with direct redemption fees once a quarter.
Timeline of treasury-relevant events
| Date | Event |
|---|---|
| March 2023 | USDC falls to US$0.87 after SVB |
| Q1 2025 | ESMA's deadline for CASPs to restrict non-compliant stablecoins (ESMA) |
| 1 Jul 2026 | MiCA transitional period ends |
| 30 Oct 2026 | Coinbase converts restricted tokens for EEA retail |
| 18 Jan 2027 | GENIUS Act and OCC rule effective |
| 18 Jul 2028 | US offering ban for non-permitted issuers' tokens |
Q/A
Should we convert to fiat immediately?
That is a policy choice. Converting immediately minimises depeg and interest-ban costs. Holding gives flexibility for payouts and prefunding. Many treasuries keep a buffer sized to their next settlement window.
How many stablecoins should we hold?
Enough to cover counterparty needs and to avoid relying on one issuer, but few enough to keep operations and reconciliation simple.
Can we redeem directly with the issuer?
Usually only with institutional onboarding, minimums and sometimes fees. Most businesses redeem through a licensed ramp.
What should happen in a depeg?
Follow a pre-agreed playbook: pause acceptance, move to another token or fiat, and communicate with counterparties.
Do we need an auditor's view on stablecoin holdings?
Usually. Accounting treatment varies by framework. See Accounting, reconciliation and tax.
Is self-custody safer than a custodian?
It removes custodian risk but adds key-management risk. See Custody and wallet security.
Sources
- private.law, Stablecoins: Types and Regulation: https://wiki.private.law/en/stablecoins
- DefiLlama, stablecoins data (read 29 October 2026): https://defillama.com/stablecoins
- Finzil (18 October 2026): https://finzil.com/blog/igaming-payment-challenges
- Circle, transparency: https://www.circle.com/transparency
- CNBC, USDC breaks dollar peg after US$3.3bn SVB exposure (11 March 2023): https://www.cnbc.com/2023/03/11/stablecoin-usdc-breaks-dollar-peg-after-firm-reveals-it-has-3point3-billion-in-svb-exposure.html
- ESMA, Statement on non-MiCA compliant ARTs and EMTs (17 January 2025): https://www.esma.europa.eu/sites/default/files/2025-01/ESMA75-223375936-6099_Statement_on_stablecoins.pdf
FiatDesk Wiki is educational. Not financial or legal advice.