Taiwan's New Accounting Standards for Stablecoins: A Quick Guide to Accounting for USDC and USDT
Introduction: Why Does Taiwan Need These Guidelines?
When a Taiwanese listed company purchases machinery and equipment with Bitcoin, how should it be recorded in its financial statements? When customers switch to paying with USDC for goods, how much sales revenue should be recognized? A few years ago, these questions were niche topics, but as more and more listed and OTC-listed companies in Taiwan begin to actually hold and trade stablecoins, these issues have become urgent practical needs.
In response to this demand, under the guidance of the Financial Supervisory Commission, and commissioned by the Taiwan Stock Exchange and the Taipei Exchange, a task force formed by the Accounting Research and Development Foundation officially released the "Guidelines for Accounting Treatment of Stablecoin Transactions" on May 27, 2026. These guidelines focus on the two stablecoins most commonly used by Taiwanese enterprises—USDC (issued by Circle Internet Financial) and USDT (issued by Tether International)—providing a systematic IFRS accounting framework.
This article translates these technical guidelines into an easy-to-understand analytical piece, to help financial executives, accountants, and business decision-makers quickly grasp the core principles.
I. What Exactly Are Stablecoins? First, Let's Clarify What They Are Not.
Before discussing classification, the guidelines first draw several distinctions.
Stablecoins Are Not Subject to the "Cryptocurrency Agenda Decision"
The IFRS Interpretations Committee (IFRS IC) issued an agenda decision on "Holdings of Cryptocurrencies" in 2019, establishing the principle that cryptocurrencies like Bitcoin should be accounted for under IAS 2 (Inventories) or IAS 38 (Intangible Assets). However, this logic cannot be directly applied to stablecoins for the following reasons:
- Stablecoins have clear issuers: Circle issues USDC, and Tether issues USDT—this is fundamentally different from cryptocurrencies that are "not issued by any institution."
- Stablecoins involve contractual relationships: There is a user contract between the holder and the issuer, which may grant the right to redeem for fiat currency—this violates the condition of "not giving rise to a contract between the holder and another party."
While this determination may seem technical, it has significant implications: precisely because stablecoins involve contractual relationships, they can potentially be classified as financial assets, rather than intangible assets.
Stablecoins Are Also Not Cash
Although USDC and USDT are functionally similar to currency, and can be used as a means of payment or a unit of pricing for goods, according to IAS 32, "cash" must be the medium that forms "the basis for measuring and recognizing all transactions in financial statements." Currently, stablecoins have not yet reached this level of widespread acceptance; therefore, stablecoins cannot be recognized as cash at this stage.
II. Decision Tree: Four Possible Classifications for Stablecoins
The guidelines provide a clear decision tree logic, allowing enterprises to systematically determine the accounting classification of stablecoins:
Acquiring Stablecoins
│
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A. Does it qualify as 'cash'?
→ No (stablecoins currently do not qualify)
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B. Does it qualify as a 'financial asset'? (Does the holder have a contractual right to receive cash?)
→ Yes → Further determine if it is a 'cash equivalent' (C) or other financial asset
→ No → Proceed to D
│
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C. Does it qualify as a 'cash equivalent'?
→ Yes → Account for it as a cash equivalent under IAS 7
→ No → Account for it as a financial asset under IFRS 9 (e.g., FVPL)
│
▼
D. Is it held for sale in the ordinary course of business?
→ Yes → Inventory (IAS 2)
→ No → Intangible Assets (IAS 38)
The key lies in B: Do holders truly have a "contractual right" to redeem cash from the issuer? The answer to this question depends on three real-world scenarios—which are the four cases outlined in the guidance.
III. Three Scenarios, Four Cases: A Detailed Breakdown
[Scenario 1] Stablecoins Have Achieved Legislative Regulation
This is the ideal state and the future direction for stablecoins to move towards mainstream finance.
According to the U.S. "GENIUS Act" (signed by the U.S. President on July 18, 2025, and expected to take effect by January 18, 2027 at the latest), once a stablecoin issuer obtains a license in accordance with the law, they must:
Have a legal obligation to redeem at par value at any time for any holder (regardless of nationality or location)
Redemption restrictions can only be implemented by the competent authority in accordance with the law; issuers may not exercise their own discretion
May not pay interest to holders
Under this framework, holders' contractual rights are legally protected. Both USDC and USDT meet the definition of financial assets under IAS 32 and should be recognized as "Financial Assets at Fair Value Through Profit or Loss (FVPL)" in accordance with IFRS 9.
Accounting Treatment Summary (Case 1):
Practical Example:
On August 15, 2025, Taipei Company sold a batch of laptops and received 120,000 USDC. At that time, the exchange rate was USD/NTD = 31, and the fair value of USDC was 1 USD:
- Recognize financial asset: 120,000 × 1 × 31 = NTD 3,720,000
- Recognize sales revenue: NTD 3,720,000
By December 31, 2025, the exchange rate had dropped to 29, while USDC still maintained a value of 1 USD:
- The book value decreased to 3,480,000, recognizing a "financial asset revaluation loss" of 240,000.
Redeemed on 2026/1/15, with the exchange rate recovering to 30:
- Remeasured value of 3,600,000, recognizing a "financial asset revaluation gain" of 120,000, and converting to a bank deposit of 3,600,000.
Scenario 2: Stablecoins are not legislated, but the enterprise has passed the issuer's KYC review.
This is the current reality for most Taiwanese enterprises.
Taking USDC as an example, Circle's user terms explicitly state that only users who have passed KYC (identity verification), AML (Anti-Money Laundering), and CFT (Combating the Financing of Terrorism) reviews have the right to redeem USD from Circle. It appears that Taipei Company "does have" contractual rights—but the problem is:
> Circle reservesthe right to modify terms without user consent,and also reserves the right tosuspend or refuseuser redemptions under specific circumstances.
Tether's situation is even more direct: the terms explicitly state that Tether unilaterally decides whether to delay or suspend redemptions.
This means that the holder's redemption rights may be canceled at any time, thus not meeting the definition of a financial asset under IAS 32.
Classification result: Intangible asset (IAS 38, indefinite useful life)
Accounting Treatment Summary (Case 2):
Key difference: In Case 1, exchange rate changes are immediately reflected in profit or loss; in Case 2, if the exchange rate rises, causing the recoverable amount to exceed the book value, no revaluation gain is recognized (IAS 38 cost model), and only a decrease in value results in the recognition of an impairment loss.
Varying Treatment of USDT Transaction Fees:
- Case 1 (Financial Asset): Transaction fees are recognized as current period expenses
- Case 2 (Intangible Asset): Transaction fees are included in the asset's acquisition cost
Although this difference may seem like a minor detail, it has a practical impact on financial statement presentation.
Scenario 3: Stablecoins are not legislatively regulated, and the company has not passed the issuer's verification
This is the most common and restricted scenario: companies buy and sell stablecoins on secondary markets (e.g., Coinbase, MaiCoin, BitoPro) but have not completed KYC verification with Circle or Tether, and thus have no direct channel to redeem fiat currency from the issuer.
Conclusion is the same: Does not meet the definition of a financial asset under IAS 32 → Recognized as an intangible asset (IAS 38)
However, one detail is worth noting: the company in Case 3 purchases USDT from a third-party exchange without paying transaction fees, and the initial recognition is directly recorded at the purchase price.
Treatment upon sale:
Taipei Company holds 120,000 USDC with a book value of NT$3,660,000, and ultimately sold them on an exchange at NT$29.9 each:
- Received NT$3,588,000
- Recognized a loss on disposal of intangible assets of NT$72,000
Scenario 4: Acquiring stablecoins through virtual asset swaps
Company B exchanges Ethereum obtained from mining pools for USDC via a third-party exchange—this is a "non-monetary asset exchange" and is subject to the provisions of paragraphs 45-47 of IAS 38.
Determining whether commercial substance exists:
The cash flow patterns (amount, timing, risk) of USDC and Ethereum are significantly different; therefore, the exchange has commercial substance, and the acquired asset should be measured at fair value.
Recognition method:
The acquired USDC intangible asset is recognized at the fair value of the exchanged Ethereum (10 units × 2,200 USDC/ETH × 31 NTD = 682,000 NTD).
IV. Three Core Differences: Financial Assets vs. Intangible Assets
Having understood the four cases, we can summarize the three most critical differences between the two classifications:
1. Asymmetry in Profit and Loss Direction
Companies using FVPL will have higher volatility in their financial statement profits, but can reflect market prices in a more timely manner.
Companies using the intangible asset model have relatively stable earnings, but face an asymmetric pressure where "losses are recognized, but gains are not."
2. Differences in Foreign Currency Translation Treatment
Financial assets (monetary items): According to IAS 21, paragraph 23, translated at the closing exchange rate on the reporting period end date, with exchange differences recognized in profit or loss.
Intangible assets (non-monetary items): According to IAS 21, paragraph 23(b), translated at the exchange rate on the date of the transaction, with no subsequent adjustment to the carrying amount exchange rate; however, during impairment testing, the recoverable amount is translated according to paragraph 25 using the "exchange rate on the date the value is determined."
3. Recognition Method for Transaction Costs
V. Key Judgment Points in Business Practice
Although the guidance provides a clear framework, real-world situations are often more complex. When determining the classification of stablecoins, enterprises should pay special attention to the following points:
1. Contract Terms Can Change, and Classifications Must Be Updated Accordingly
Issuers may update user terms at any time. For example, if Tether modifies its terms in the future, restricting the right to "discretionarily delay redemption" to be exercised only in cases of "user default or systemic risk," USDT might then be reclassified from an intangible asset to a financial asset. Enterprises should continuously monitor the issuer's latest published user terms.
2. Regulatory Status Is the Most Important Trigger
The GENIUS Act is expected to take effect by January 2027 at the latest. If USDC/USDT issuers obtain licenses after it takes effect, stablecoins held by Taiwanese enterprises may need to be re-evaluated for classification. Financial executives should prepare in advance before the regulation takes effect.
3. Fair Value Measurement Requires Consistency
Regardless of the classification, the guidance uses the "real-time price at the last trading time (23:59:59) of the primary market" as the fair value benchmark. Enterprises should select a consistent market (e.g., Coinbase) and establish internal policies to avoid selecting different markets or different time points each period.
4. Cost Calculation Method Must Be Selected and Applied Consistently
When intangible assets are subject to impairment testing and disposal, the cost per unit needs to be determined. The guidance allows the use of "First-In, First-Out (FIFO)" or the "Weighted Average Method," but once selected, it should be applied consistently.
5. Disclosure Obligations Cannot Be Overlooked
Regardless of whether they are classified as financial assets or intangible assets, companies must appropriately disclose in their financial statement notes: the purpose of holding stablecoins, their quantity, the method for determining fair value, and related risks (e.g., issuer credit risk, redemption restriction risk), among others.
6. The Contemporary Significance of This Guidance
From a broader perspective, the issuance of this guidance carries several important implications:
Significance for Taiwan's Capital Market
This is Taiwan's first IFRS accounting treatment guidance specifically for stablecoin transactions, filling a long-standing institutional gap. Previously, listed companies each adopted their own practices, making it difficult for investors to compare financial statements across different entities. With this guidance, related disclosures are expected to become more consistent.
Observations on the Evolution of Accounting Standards
The core standards referenced by the guidance (IAS32, IAS38, IFRS9, IFRS13, IFRS15) were all designed for traditional financial and intangible assets and did not foresee the existence of stablecoins. This guidance demonstrates the skill of "analogous application" within the existing IFRS framework, where the legal status of stablecoin holders becomes the key pivot for accounting classification. This also foreshadows that when the IASB officially develops new standards for digital assets in the future, the substance of "contractual rights" will be the core criterion for judgment.
Implications for Enterprise Digital Transformation
More and more Taiwanese companies are using stablecoins for cross-border payments, as commercial consideration, and even as financial management tools. This guidance reminds companies that before adopting stablecoins, they must first establish an accounting policy plan—including selecting fair value sources, confirming legal status, establishing impairment testing procedures, and ensuring financial statement disclosures comply with IFRS requirements.
Conclusion
The core logic of the "Guidance on Accounting Treatment for Stablecoin Transactions" can be summarized in one sentence:
> Do you truly possess an "enforceable contractual right" to redeem fiat currency from the issuer? The answer to this question determines the fate of stablecoins on financial statements.
If there is a legally protected contractual right, stablecoins are financial assets, and fair value fluctuations are recognized immediately in profit or loss. If this right is absent or conditionally held, stablecoins are intangible assets, where only losses can be recognized, not gains.
As the global stablecoin regulatory framework gradually takes shape, this judgment will increasingly lean towards "yes." And Taiwanese enterprises and accounting professionals now have this guidance to follow, enabling them to navigate the era of digital finance more steadily and transparently.
Corporate Stablecoin Payment & Settlement Consulting
If your business is evaluating stablecoins for collections, payouts, cross-border settlements, or corporate account fiat onboarding/offboarding, feel free to fill out our consultation form. The ZONE Wallet team will assess the best integration approach tailored to your transaction scenarios, payment destinations, token types, and compliance requirements.
This article is compiled and written based on the "Guidance on Accounting Treatment for Stablecoin Transactions" (May 27, 2026). The content is for reference only; actual accounting treatment should be determined based on the latest regulations and user terms.
