FASB ASU 2023-08 (Subtopic 350-60) introduced fair-value accounting for certain crypto assets, but most fiat-backed stablecoins (USDC, USDT, USDP) are EXCLUDED from its scope. They fail the criterion that the asset must not provide enforceable rights to underlying goods, services, or other assets, because the holder has a contractual right to redeem the token for fiat. So the operative question for a corporate treasury holding stablecoins is not "how do I mark to market under ASU 2023-08?" but "which other GAAP guidance applies?" Usually that lands on financial-instruments treatment, not the new intangibles standard.
What ASU 2023-08 actually does
FASB issued Accounting Standards Update 2023-08 in December 2023, creating Subtopic 350-60 within the Intangibles (Goodwill and Other) topic. The update requires in-scope crypto assets to be measured at fair value through net income, with changes recognized each reporting period. Disclosure requirements expanded too: significant holdings, restrictions on sale, and reconciliations of opening and closing balances.
The standard is effective for fiscal years beginning after December 15, 2024. Calendar-year public companies adopted it on January 1, 2025. Calendar-year private companies adopted on January 1, 2026. Early adoption is permitted.
The change matters because the prior treatment (cost-less-impairment as an indefinite-lived intangible) produced asymmetric reporting: losses recognized, gains stuck on the balance sheet until sale. Fair-value accounting fixed that. But it only fixed it for the crypto assets that actually meet the scope criteria.
The five scope criteria (and why stablecoins usually fail one of them)
To fall inside Subtopic 350-60, a crypto asset must meet all five of these criteria.
Meet the GAAP definition of an intangible asset.
NOT provide the asset holder with enforceable rights to or claims on underlying goods, services, or other assets.
Reside on a distributed ledger.
Be secured by cryptography.
Be fungible.
And one more: the asset must not have been created or issued by the reporting entity.
Fiat-backed stablecoins generally fail criterion 2. A holder of USDC has a contractual right to redeem the token for one US dollar of underlying reserves. A holder of USDT has the same. A holder of USDP, USDG, or PYUSD likewise. That redemption right is exactly what makes a stablecoin a stablecoin, and it is exactly what pushes the holding out of Subtopic 350-60.
Bitcoin, ether, and similar tokens have no such enforceable claim against an issuer, so they sit inside the scope. Stablecoins typically sit outside.
So what GAAP DOES apply to USDC on the balance sheet?
FASB did not paint a single bullseye for stablecoins. The answer depends on the specific rights and obligations of the token. The Deloitte FAQ on ASU 2023-08 (April 2024, last updated July 21, 2025) walks through several alternatives:
Financial instrument or financial asset. If the stablecoin represents a contractual right to receive cash from the issuer, the holder may be applying ASC 825, ASC 320, or other financial-instruments guidance. This is the most common landing zone for fiat-backed stablecoins held by US corporates.
Cash or cash equivalent. Some treasury teams have asked whether a tokenized US dollar with a same-day redemption claim should be classified as cash. The answer turns on whether the token meets the ASC 305-10 definition of cash. Most do not, because they are not legal tender and conversion to fiat depends on issuer cooperation.
Other intangible asset. If a particular stablecoin somehow does fall outside both 350-60 and financial-instruments scope, ASC 350-30 (indefinite-lived intangibles, cost-less-impairment) is the backstop.
The practical answer for most US corporates holding USDC or USDT: treat it as a financial asset under the appropriate sub-topic, fair-valued at the reporting date, with the basis disclosed.
Journal entries for a treasury holding USDC
The mechanics are straightforward once the classification is settled. Below is a simplified flow for a corporate treasury that buys US$10 million of USDC, holds it for a quarter, and redeems half at par.
Event | Debit | Credit |
Acquire 10M USDC | Digital asset (financial asset) 10,000,000 | Cash 10,000,000 |
Quarter-end fair value at $1.0000 (no change) | No entry | No entry |
Quarter-end fair value at $0.9990 (peg dip) | Unrealized loss 10,000 | Digital asset 10,000 |
Redeem 5M USDC at par | Cash 5,000,000 | Digital asset 5,000,000 |
The peg-dip entry is what changed under fair-value accounting. Under the prior indefinite-lived intangibles treatment, the loss would have been recognized as impairment, then never reversed. Under fair-value, a recovery back to one dollar at the next reporting date reverses the loss.
Disclosures a corporate treasury should be prepared to make
Even when stablecoins are accounted for under financial-instruments guidance rather than Subtopic 350-60, US public companies are subject to broader disclosure expectations: fair-value level (Level 1, 2, or 3), counterparty concentration if holdings are with a single issuer, restrictions on conversion, and any custody arrangements that move the asset out of direct corporate control.
Internal controls also matter. SOX-relevant controls over private-key custody, transaction approval, and reconciliation of onchain balances to the general ledger are the operational backbone that auditors will look at first.
Why this matters for a treasury team in 2026
Two adoption waves have just landed. Public companies were on fair-value-eligible crypto starting January 2025. Private companies adopted in January 2026. Many treasury teams reflexively assumed stablecoins were caught in the same net. They mostly are not. Misapplying Subtopic 350-60 to a fiat-backed stablecoin overstates the assurance from a standard that does not govern the holding.
The right move is to read the issuer's redemption terms first, confirm whether the stablecoin grants an enforceable claim, and then route the holding to financial-instruments accounting if it does. Subtopic 350-60 is the right home for bitcoin and ether on the balance sheet. It is not the right home for the USDC sitting in the operating account.
Methodology and sources
The scope analysis follows the Deloitte FAQ on ASU 2023-08 (April 2024, last updated July 21, 2025), the FASB final standard text (fasb.org), and the Grant Thornton snapshot published December 2023. All five scope criteria and the fiat-backed-stablecoin exclusion are stated directly in those primary sources.
Related reading
PLACEHOLDER-how-to-read-stablecoin-attestation-report-line-by-line
PLACEHOLDER-stablecoin-regulation-singapore-hong-kong-uae
PLACEHOLDER-genius-act-1-year-implementation-tracker

