Key takeaways
- Section 4(a)(1)(C) of the GENIUS Act requires a permitted payment stablecoin issuer to publish the monthly composition of its reserves on its website.
- Each report must show total stablecoins outstanding and the amount and composition of reserves, with the average tenor and geographic location of custody for each category.
- A registered public accounting firm must examine the month-end report every month, under section 4(a)(3)(A).
- The chief executive officer and chief financial officer must certify its accuracy to the regulator; a knowingly false certification carries the criminal penalties in 18 U.S.C. 1350(c).
- Issuers with more than $50 billion outstanding that are not SEC reporting companies must also publish annual audited financial statements.
What are the key facts on the monthly reserve report?
The monthly reserve report is the public, examined and certified statement of what backs a US payment stablecoin.
| Item | Position |
|---|---|
| Rule | GENIUS Act section 4(a)(1)(C) and 4(a)(3) |
| Regulators | The issuer's primary federal or state payment stablecoin regulator |
| Applies to | Permitted payment stablecoin issuers |
| Frequency | Monthly, published on the issuer's website and examined each month |
| Effective | Earlier of January 18, 2027 or 120 days after final regulations |
| Last checked | October 11, 2026, against Public Law 119-27 and OCC Bulletin 2026-3 |
What must the report show?
It must show tokens outstanding and, for each reserve category, the amount, average tenor and where the assets are held.
Under section 4(a)(1)(C) of the enacted text, the issuer must publish the monthly composition of its reserves on its website, containing the total number of outstanding payment stablecoins and the amount and composition of the reserves, including the average tenor and geographic location of custody of each category of reserve. The categories follow the eight eligible classes in section 4(a)(1)(A); our guide to GENIUS Act eligible reserves lists them.
| Element | What it means in practice |
|---|---|
| Total payment stablecoins outstanding | Supply on every network at the cut-off, less tokens held by the issuer that are not in circulation |
| Amount of reserves | The value of eligible reserves at the same cut-off |
| Composition by category | Separate figures for deposits, Treasuries, repos, money market funds and any other eligible class |
| Average tenor per category | The weighted average time to maturity of the assets in each category |
| Geographic location of custody | Where each category is held, by country or location of the custodian |
The report is public, so it is read by holders, counterparties, exchanges and journalists as well as the regulator. A consistent layout each month, with the same categories in the same order and the cut-off time stated, makes month-to-month changes easy to follow and reduces the questions that follow publication. Issuers that also publish under other regimes, such as New York or the EU, should keep the GENIUS categories separate rather than merging them into a single combined table.
Who examines the report, and how often?
A registered public accounting firm examines it every month.
Section 4(a)(3)(A) requires the issuer to have the information disclosed in the previous month-end report examined each month by a registered public accounting firm. The provision cross-refers to paragraph (1)(D), while the reporting duty itself sits in paragraph (1)(C), so firms should follow the regulator's implementing rules on the point. The examination tests both sides: the count of tokens outstanding and the existence, value and eligibility of each reserve asset. Because it happens every month, the accounting firm will want standing access to statements, wallet data and the reconciliation log, rather than a fresh request each time. Our guide to proof of reserves and attestation explains why an accountant's examination gives more assurance than a self-published wallet list.
What does the CEO and CFO certification involve?
The chief executive officer and chief financial officer certify to the regulator each month that the report is accurate.
Under section 4(a)(3)(B) the certification goes to the issuer's primary federal payment stablecoin regulator or state regulator. Section 4(a)(3)(C) applies to anyone who knowingly submits a false certification the same criminal penalties as section 1350(c) of title 18 of the US Code, the Sarbanes-Oxley certification offence, which provides fines of up to $1 million and up to 10 years' imprisonment for knowing violations, and up to $5 million and 20 years for willful ones. In practice, the two officers need a documented sub-certification chain: who prepared each figure, who reconciled it, which differences were open at month end and how they were resolved.
How do the layers of assurance fit together?
The Act stacks four layers: the issuer's own records, a monthly examination, a monthly certification and, for the largest issuers, an annual audit.
| Layer | Who | Frequency | Source in the Act |
|---|---|---|---|
| Reserve records and reconciliation | The issuer | Continuous; identifiable reserves at all times | Section 4(a)(1)(A) |
| Public reserve report | The issuer | Monthly | Section 4(a)(1)(C) |
| Examination of the month-end report | Registered public accounting firm | Monthly | Section 4(a)(3)(A) |
| Accuracy certification | CEO and CFO | Monthly | Section 4(a)(3)(B) |
| Audited annual financial statements | Registered public accounting firm | Annually, above $50 billion outstanding | Section 4(a)(10) |
Each layer relies on the one below it. The examination can only sample what the issuer's records contain, and the officers can only certify what the examination and the records support.
Is there an annual audit as well?
Yes, for issuers with more than $50 billion of consolidated outstanding issuance that are not already SEC reporting companies.
Section 4(a)(10) requires such issuers to prepare annual financial statements under US GAAP, including disclosure of related party transactions, have them audited by a registered public accounting firm, publish them on their website and submit them to their primary regulator. For these issuers, the twelve monthly reports and the audited year-end balance sheet must reconcile with each other.
How does the monthly report connect to daily operations?
The monthly report is only as reliable as the daily reconciliation of tokens and reserves behind it.
Tokens are minted and burned every day, often on several networks, and reserves move between banks, custodians and funds as redemptions are paid. If the issuer reconciles only at month end, any difference found then has to be explained under deadline, with the certifying officers waiting. If it reconciles daily, month end is simply the last day of a series that has already been checked, and the examiner can sample any day in the month and find the same answer. The daily routine has four parts: read supply on every network at a fixed time, agree it to the issuance ledger, agree reserve balances to statements, and compare eligible reserves with tokens outstanding.
What problems come up when preparing the report?
Most problems arise from timing, classification and token count, not arithmetic.
- Cut-off: on-chain supply read at midnight UTC compared with bank balances at New York close produces a gap that is only timing.
- Bridged tokens: tokens locked in a bridge contract on one network and minted on another can be counted twice if both supplies are added.
- Treasury wallets: tokens pre-minted and held by the issuer are not outstanding, but must be shown to be under the issuer's control.
- Classification: a Treasury bill bought with more than 93 days to run is not eligible until its remaining maturity falls to 93 days, so it may need to be shown outside the eligible categories.
- Tenor: average tenor should be weighted by amount, not a simple average of holdings.
- Custody location: a custodian incorporated in one country may hold assets through a sub-custodian in another; the report should reflect where the assets are held.
A short memo each month explaining any reconciling items, signed by the preparer and reviewer, gives the examiner and the certifying officers a single place to see what was resolved and how.
What do the implementing rules add?
They add the detail on format, timing and supervisory reporting.
The Act does not fix the day of the month by which the report must be published. The OCC's proposed 12 CFR part 15, announced in OCC Bulletin 2026-3 on February 25, 2026, covers audits, reports and supervision alongside reserve assets and redemption. Issuers should build to the statutory content now and adjust timing and format when their regulator's final rule is published.
What does a completed monthly report look like?
The example shows a month-end report for a fictional issuer, followed by the reconciliation behind the token count.
| Reserve category | Amount ($m) | Average tenor | Custody location |
|---|---|---|---|
| Demand deposits at insured banks | 260.0 | On demand | United States |
| Treasury bills within the 93-day test | 1,240.0 | 41 days | United States |
| Overnight reverse repos, tri-party | 400.0 | 1 day | United States |
| Government money market fund | 130.0 | 28 days (fund weighted average maturity) | United States |
| Total reserves | 2,030.0 | ||
| Payment stablecoins outstanding | 2,000.0 | ||
| Reserve ratio | 101.5% |
| Token count reconciliation | Tokens (m) |
|---|---|
| Supply on Ethereum | 1,420.0 |
| Supply on Solana | 510.0 |
| Supply on Base | 95.0 |
| Total supply on all networks | 2,025.0 |
| Less tokens in issuer treasury wallets, not in circulation | (25.0) |
| Payment stablecoins outstanding | 2,000.0 |
The examiner will agree each network's supply to a block at the cut-off time, confirm the treasury wallets are controlled by the issuer, and match the reserve figures to bank, custodian and fund statements at the same moment. A $5.0 million difference between the issuance ledger and on-chain supply, for example a mint recorded after the cut-off, would need to be explained before the CEO and CFO sign.
What should be in place before the first report?
These controls make the first examined report routine rather than a scramble.
- Fix a single cut-off time for on-chain supply, bank, custody and fund balances.
- Reconcile tokens outstanding to the issuance ledger every day, not only at month end.
- Classify every reserve holding by eligible category and record tenor and custody location.
- Keep a log of differences found and how each was resolved during the month.
- Agree the examination scope and evidence list with the accounting firm in advance.
- Document the sub-certification chain that supports the CEO and CFO certification.
- Publish the report on the website in a consistent format each month.
Our guide to stablecoin reserve reconciliation sets out the daily process behind these steps.
How does Safeheld help?
Safeheld reconciles on-chain supply, the issuance ledger and reserve accounts every day and keeps the history the examiner samples.
Each month-end figure links to the reconciliation and break records behind it, which supports the officers' certification. See regulatory evidence and what the GENIUS Act is.
Frequently asked questions
What must a GENIUS Act monthly reserve report include?
The total number of payment stablecoins outstanding and the amount and composition of reserves, including the average tenor and geographic location of custody of each reserve category.
Where is the monthly reserve report published?
On the issuer's website, under section 4(a)(1)(C).
Who examines the monthly report?
A registered public accounting firm, every month, under section 4(a)(3)(A).
Who certifies the monthly report?
The issuer's chief executive officer and chief financial officer, who certify its accuracy to the primary regulator.
What is the penalty for a false certification?
A knowingly false certification carries the same criminal penalties as 18 U.S.C. 1350(c): up to $1 million and 10 years for knowing violations, and up to $5 million and 20 years for willful ones.
Do large issuers need audited financial statements?
Yes. Issuers with more than $50 billion outstanding that are not SEC reporting companies must publish annual audited GAAP financial statements.
Does the Act set a publication deadline within the month?
No. The Act requires monthly publication and a monthly examination of the previous month-end report, but leaves detailed timing and format to the implementing rules.
When does the monthly report start?
When the Act takes effect: the earlier of January 18, 2027 or 120 days after final implementing regulations.
References
- Public Law 119-27, Guiding and Establishing National Innovation for U.S. Stablecoins Act (govinfo.gov)
- Public Law 119-27, enrolled text (PDF)
- OCC Bulletin 2026-3, Notice of proposed rulemaking implementing the GENIUS Act (February 25, 2026)
About Safeheld
Safeheld is reconciliation and regulatory financial control software for regulated firms that hold client money. For stablecoin issuers it reconciles tokens outstanding, reserves and custody balances every day and keeps the evidence behind each monthly report, which the issuer publishes and certifies. To discuss your reserve operations, contact us at safeheld.com/contact.
This article is general information on US stablecoin and digital asset rules and is not legal or regulatory advice.