What FASB's 2026 stablecoin proposal means for your books

What was issued

The proposal is titled “Statement of Cash Flows (Topic 230): Cash Equivalents—Disclosure Enhancement and Evaluation of Certain Digital Assets”. It came out of a project FASB added to its agenda on 29 October 2025, after the GENIUS Act was signed in July 2025. The board completed initial deliberations on 15 April 2026 and chose to add illustrative examples rather than write a new definition of a cash equivalent.

The three cases

The examples would sit in ASC 230-10-55-22 to 55-28. The Master Glossary definition of a cash equivalent does not change.

• Case A, qualifies. Reserves are segregated and held 1:1 in cash and Treasury bills of three months or less, and the entity has a direct, on-demand contractual right to redeem at $1 with no significant fees or restrictions.
• Case B, fails. The same coin, but the entity has no account with the issuer and can only sell on secondary markets. Secondary-market liquidity is not enough.
• Case C, fails. Reserves are held in crypto or gold, so the risk of a change in value is more than insignificant.

Where a typical small business lands

Circle's USDC terms separate holders with a Circle Mint account (User Type A, institutions) from everyone else (User Type B). A business paid in USDC to a self-custodied wallet or an exchange account is Type B: not a Circle customer, with no direct redemption right. That is the fact pattern of Case B. Under the proposal as written, that holding would not be a cash equivalent.

A business that does hold a direct issuer account would need to look at the Case A conditions: reserve composition and segregation, redemption fees and restrictions, and the issuer's regulatory status. Cash-equivalent classification remains an entity policy (ASC 230-10-45-6), elected and documented.

What the proposal does not decide

It does not say how a stablecoin that fails the cash-equivalent test is accounted for. That question stays where it is today, with diverse practice: a financial asset where the holder has or can readily obtain a redemption right (AICPA Q&A 23, KPMG Q 8.4.10), or an intangible asset under ASC 350-30 or, on a strict reading, ASC 350-60. See Is USDC cash? for those views.

New disclosure for everyone with cash equivalents

Separately from stablecoins, the proposal adds an annual disclosure for all entities with cash equivalents: the significant classes and their amounts, such as Treasury bills, commercial paper, money market funds and stablecoins. It would reach businesses that never touch a stablecoin.

Transition

• Classification applies on a modified prospective basis from the start of the year of adoption.
• A reconciliation of opening cash, cash equivalents and restricted cash is presented; no preferability assessment is required.
• The disclosures apply prospectively.

How it interacts with the GENIUS Act

The proposal says an entity considers compliance with laws and regulations when setting its cash-equivalent policy. GENIUS Act §3(g) provides that a payment stablecoin not issued by a permitted payment stablecoin issuer shall not be treated as cash or as a cash equivalent for accounting purposes. The Act takes effect on the earlier of 18 January 2027 or 120 days after final regulations; sources differ on whether §3(g) bites then or with the offer-and-sale prohibition in 2028. Which issuers will be permitted is not yet known. Both points need counsel.

What to do with this now

Nothing in the proposal is effective, and it can change after comments. Practically, the useful work is to write down the facts the final standard will turn on: which tokens the business holds, where, whether it has an account with any issuer, and which classification policy the accountant applies today and why. When a final ASU arrives, a documented policy can be moved to a new version from a chosen period, without restating closed months.

Gladpaid stores the treatment as a versioned policy with its citations. If FASB finalises the proposal, a new policy version is published and each business sees what changed and chooses the period to adopt it from. See Treatment policy.

This guide describes how published standards and guidance treat these transactions, and where that guidance is unsettled. It is not accounting, tax or legal advice. The treatment for your business is your accountant's decision.