Stablecoin Readiness for Enterprises: What Has to Change Before the First Payment

The short answer

Almost nothing about stablecoin adoption is a crypto problem for an enterprise buyer. It is a finance operations problem. Before a company can pay a supplier in stablecoins, five things have to change internally: how treasury holds and moves the balance, how the ERP records it, how the finance function classifies it on the balance sheet, how compliance monitors the counterparty and the chain, and who in the organisation is accountable for the decision.

None of those five require a view on blockchain. All five require an operating model change, and most enterprises that describe themselves as ready have addressed only the first one.

The evidence supports that gap. In the 2025 EY-Parthenon stablecoin survey of 350 corporate and financial institution decision-makers, 13 per cent of organisations had used stablecoins, while 54 per cent of non-users expected to adopt within six to twelve months. In the same survey, 41 per cent of corporates said they could integrate stablecoins with moderate effort and 36 per cent said it would require major systems change. Intent has moved considerably faster than capability.

What changed between 2023 and now

Until recently the honest answer to "should we use stablecoins" was that the regulatory position was unresolved, so the question could reasonably be deferred. That answer has expired.

The United States enacted the GENIUS Act on 18 July 2025, creating the first federal framework for payment stablecoins. The European Union's rules for asset-referenced and e-money tokens under MiCA have applied since 30 June 2024. Hong Kong's Stablecoins Ordinance took effect on 1 August 2025, and on 10 April 2026 the Hong Kong Monetary Authority granted the first two issuer licences, to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited. The Bank of England published its policy statement and draft Code of Practice for sterling systemic stablecoins in June 2026.

That is a material change in the nature of the question. When the regulatory answer was genuinely unknown, waiting was a defensible strategy. Now that frameworks exist, the binding constraint has moved inside the enterprise, and waiting is a decision rather than a default.

One further development, largely unnoticed outside finance functions, matters more to a corporate treasurer than any of the licensing news. On 18 August 2026 the Financial Accounting Standards Board issued a proposed Accounting Standards Update clarifying when certain digital assets, including stablecoins, meet the definition of a cash equivalent under US GAAP. Under the proposal, a qualifying asset would need an on-demand contractual redemption right, a direct redemption right with the issuer for a known cash amount, and segregated reserves held at no less than one-to-one in short-term, highly liquid assets. The comment period runs to 19 November 2026.

It is a proposal, not settled guidance, and it may change before it is finalised. But it addresses precisely the obstacle that half of US respondents in the EY-Parthenon survey named, and it is the item most likely to move a CFO from interested to committed. Cash equivalent presentation puts a qualifying holding alongside money market funds rather than in a separate digital asset line that invites audit scrutiny and signals volatility to investors.

What a stablecoin is, briefly

A stablecoin is a digital token designed to hold a steady value by reference to an external asset, most commonly a single fiat currency. It differs from other cryptocurrencies in intent rather than in underlying technology: the point is not price appreciation, it is that the price does not move. That is what makes it usable for a payment or a payable balance.

Three designs exist. The differences matter for enterprise risk assessment rather than as theory.

The regulated frameworks now emerging concentrate almost entirely on the first category. The GENIUS Act, MiCA's e-money token regime and Hong Kong's ordinance are all built around reserve-backed tokens carrying redemption rights. For an enterprise, that narrows the practical question considerably: the instruments a treasury function is likely to be permitted to hold are fiat-collateralised and issued by a licensed entity. Roughly 310 billion US dollars of stablecoin value was in circulation in August 2026, overwhelmingly dollar-denominated and reserve-backed.

If you want the mechanics of what happens when the third design fails, our earlier analysis of the 2022 crypto market collapses covers the sequence in detail.

Where enterprises actually are

The EY-Parthenon survey was fielded between 10 and 24 June 2025 across 250 corporates and 100 financial institutions, weighted towards the United States. It is the most useful public dataset on this question because it separates the two populations and asks about internal readiness rather than sentiment. Its findings are worth stating precisely, because they are frequently misquoted.

Two things follow from reading the survey carefully. First, the barrier data was collected before the GENIUS Act was signed, so the 73 per cent regulatory uncertainty figure describes a world that no longer exists in the same form. Second, and more usefully, the barriers sitting underneath it were never regulatory. Accounting and tax treatment clarity was named by 38 per cent overall and by 50 per cent of US respondents. Operational complexity followed at 32 per cent. Limited banking partner support was named by 51 per cent of European respondents.

Those are internal constraints. They do not resolve themselves when a regulator publishes a rule.

The five things that have to change

Enterprises tend to scope stablecoin adoption as a payments project and hand it to treasury or to a payments product owner. That framing is where most pilots stall, because four of the five things that must change sit outside the payments function entirely.

The five domains below are ordered by how early they become blocking, not by how much work each involves.

1. Treasury and settlement operations

The first question is not which stablecoin, it is where the balance sits and who can move it. A stablecoin holding requires a custody arrangement, a wallet or account structure, defined signing authority, and a documented process for converting to and from fiat at both ends of a transaction.

That last point is where cost savings are won or lost. The 41 per cent of users reporting savings of 10 per cent or more are comparing against correspondent banking fees and multi-day settlement. If your conversion route back to fiat is expensive or slow, the saving disappears into the on and off ramp.

Practical questions to answer: which entity in the group holds the balance, what is the cash concentration policy for a 24-hour settlement asset, and what happens on a weekend when the token settles instantly but the bank does not.

2. The system of record

This is the constraint enterprises consistently underestimate, and the survey data is unusually clear about it. Approximately 70 per cent of corporates said they would be more willing to adopt if stablecoins were integrated into their ERP, and 56 per cent said their preferred integration approach was embedded APIs within their existing treasury or payment platforms rather than a separate provider.

Read that as a statement about operating cost. A payment method that does not reconcile automatically into the ERP creates manual work in accounts payable, accounts receivable and month-end close. At pilot volumes that is tolerable. At production volumes it consumes the efficiency the payment method was adopted to deliver. An organisation running a stablecoin pilot through a spreadsheet has not tested the thing that will determine whether it scales.

3. The accounting and tax position

Until the FASB proposal is finalised, a US filer's presentation of stablecoin holdings is a judgement that has to be documented and agreed with auditors in advance, not discovered at year end. Outside the US, treatment varies by jurisdiction and depends on how local rules characterise the instrument.

The questions a finance function needs settled before a first payment: how the holding is presented on the balance sheet, how gains and losses on any peg deviation are recognised, what the indirect tax treatment of a stablecoin-settled invoice is in each jurisdiction involved, and whether the treatment differs when the counterparty is intercompany rather than third party.

None of this is exotic. It is the ordinary work of introducing a new financial instrument, and it takes ordinary finance time. Enterprises get into difficulty by starting the payment before starting this conversation.

4. Compliance, counterparty and chain risk

Stablecoin transactions introduce two risks that traditional payments do not, and remove none of the existing ones.

The first is issuer and reserve risk. When you hold a fiat-collateralised stablecoin you are an unsecured claimant on a reserve pool you did not select. Whether that reserve is segregated, what it is invested in, who attests to it and how redemption behaves under stress are third-party risk management questions, and they belong in the same framework that governs any other financial counterparty.

The second is chain-level exposure. Settlement happens on a public ledger, which means transaction monitoring, sanctions screening and address risk become live operational concerns. Treasury's payment to a supplier can be traced, and the supplier's onward use of those funds is visible in a way a bank transfer is not. That is an advantage for auditability and a new surface for compliance.

The Treasury Department's proposed rule implementing section 3 of the GENIUS Act, published on 18 August 2026 with comments closing on 19 October 2026, addresses prohibitions and limitations on issuance, offer and sale in the United States. The direction of travel is towards more explicit illicit-finance obligations across the chain, not fewer. Enterprises building monitoring capability now will not have to retrofit it.

For financial institutions specifically, the workflow design question here overlaps directly with the wider modernisation of KYC and AML operations. MASSIVUE Academy's AI-Powered Banking Operations micro-credential covers building agentic KYC and AML workflows that a regulator will accept, which is the adjacent capability most banks find they need before extending monitoring to on-chain settlement.

5. Decision rights and capability

The last domain is the one that determines whether the other four get resolved. Stablecoin adoption crosses treasury, financial control, tax, compliance, procurement, technology and internal audit. In most enterprises no single role holds authority across all of those, which means the default outcome is a pilot that runs until it needs a decision nobody is empowered to make.

Two structural questions decide this. Who owns the payment method as a standing responsibility once the pilot ends, and what is the escalation route when treasury and financial control disagree on presentation. If neither has an answer, the programme has a governance gap rather than a technology gap, and adding vendors will not close it.

The capability question is narrower than it appears. Nobody in the finance function needs to understand consensus mechanisms. What they need is enough shared vocabulary to challenge a vendor claim, evaluate a reserve attestation and recognise when an operational risk is genuinely new rather than merely unfamiliar. That is a matter of days of structured briefing, not a retraining programme, and it is far cheaper than the alternative of decisions made by whoever sounds most confident.

What the rules mean if you are a user, not an issuer

Most published analysis of stablecoin regulation is written for issuers, because that is who the rules bind. For an enterprise using stablecoins, the relevant question is different: which instruments will be permissible to hold and transact in, in which jurisdictions, and by when.

The practical implication is that a multinational cannot run one global policy today. Permissibility differs by jurisdiction and by entity, and a group treasury policy written as though the rules were uniform will be wrong somewhere.

A defensible sequence

The order below reflects a simple principle: resolve the things that can stop the programme before spending money on the things that cannot.

Step 2 is the one most often deferred, and deferring it is what turns a successful pilot into a programme that cannot scale. A corridor that works operationally but has no agreed accounting treatment will not be extended, because the finance function will not sign off on volume it cannot present.

Where MASSIVUE fits

It is worth being direct about scope. MASSIVUE is not a crypto advisory firm, does not select stablecoins, and does not provide accounting, tax or legal opinions. Those belong with your auditors, tax advisers and counsel, and any consultancy that offers them alongside transformation work is selling something it should not.

What MASSIVUE does is the part of this that is an operating model problem. Four of the five domains above are questions about how an enterprise is organised: which function owns a new instrument, how decision rights are allocated when a change crosses treasury, control, tax and compliance, how a process moves from pilot to standing operation, and how the people involved acquire enough working knowledge to challenge what they are told.

That is the substance of our Enterprise Transformation practice, and the capability-building side sits within AI Workforce Transformation. The pattern is one we have run before in banking: our published global bank case study describes a twelve-week operating model co-creation that cut deployment cycle time by 60 per cent and reduced cross-team dependencies from 42 per cent to 8 per cent, achieved by changing how decisions were allocated rather than by changing the technology.

The judgement in this article is editorial synthesis: the five-domain model and the sequencing are ours, drawn from transformation practice. The adoption figures are EY-Parthenon's. The regulatory positions are the regulators' own. We have kept those three things visibly separate on purpose, because a reader deciding whether to trust a claim should be able to see where it came from.

Frequently asked questions

Do we need a blockchain strategy to use stablecoins?

No. Using a stablecoin to settle an invoice is a payment method decision, in the same category as adopting a new correspondent bank or a virtual card programme. It requires a counterparty assessment, an accounting treatment, a reconciliation path and an owner. It does not require a position on distributed ledger technology, and organisations that treat it as a technology strategy question tend to route it to the wrong function and stall.

Are stablecoins treated as cash on the balance sheet?

Not automatically, and not yet with certainty in the United States. On 18 August 2026 the Financial Accounting Standards Board issued a proposed Accounting Standards Update that would clarify when a digital asset meets the cash equivalent definition under US GAAP, requiring an on-demand contractual redemption right, direct redemption with the issuer for a known cash amount, and segregated reserves of at least one-to-one in short-term, highly liquid assets. The comment period closes on 19 November 2026 and the proposal is not final. Until it is, presentation is a documented judgement to agree with your auditors in advance. Treatment outside the United States varies by jurisdiction.

What is the realistic saving from paying suppliers in stablecoins?

In the 2025 EY-Parthenon survey, 41 per cent of organisations that had used stablecoins reported cost savings of 10 per cent or more, driven mainly by cross-border payment efficiency. That figure describes the organisations that achieved savings, not an average across all users, and it is self-reported. The saving comes from removing correspondent banking fees and multi-day float, so it is largest on high-volume cross-border corridors and smallest on domestic payments, where it may not exist at all. Any business case should be built on your own corridor economics, including the cost of converting to and from fiat at both ends.

Which function should own stablecoin adoption?

Treasury should own the instrument and the settlement operation, because that is where custody, liquidity and conversion sit. But treasury cannot own the accounting position, the tax treatment or the compliance framework, and a programme placed entirely inside treasury will stop at the first of those. The workable structure is treasury as the accountable owner, with named decision rights held by financial control for presentation, by tax for jurisdictional treatment and by compliance for counterparty and chain monitoring, plus an agreed escalation route above all four.

Is it too early for a large enterprise to start?

It is early to move volume and late to start preparing. The regulatory frameworks that determine which instruments will be permissible are either in force or on published timetables, and the US statute has a backstop effective date of 18 January 2027. The internal work described here, particularly settling the accounting position and assessing an issuer as a counterparty, takes months of ordinary finance and risk time regardless of when you decide to transact. Doing that work does not commit you to adopting. Not doing it means the decision, when it arrives, gets made under time pressure.

Sources

1. EY-Parthenon, Stablecoins in focus: navigating the new digital financial landscape, September 2025. Survey of 350 respondents fielded 10 to 24 June 2025.
2. Financial Accounting Standards Board, proposed Accounting Standards Update on the application of the cash equivalents definition to certain digital assets, issued 18 August 2026, comments due 19 November 2026. See fasb.org.
3. US Department of the Treasury, GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale, proposed rule, Federal Register, 18 August 2026.
4. Office of the Comptroller of the Currency, proposed rule implementing the GENIUS Act for OCC-supervised entities, Federal Register, 2 March 2026.
5. European Banking Authority, Asset-referenced and e-money tokens under MiCA. Regulation (EU) 2023/1114, ELI reference.
6. Hong Kong Monetary Authority, Granting of stablecoin issuer licences, 10 April 2026, and the Register of Licensed Stablecoin Issuers.
7. Bank of England, Sterling-denominated systemic stablecoins: policy statement and draft Code of Practice, June 2026.
8. Monetary Authority of Singapore, MAS finalises stablecoin regulatory framework, 15 August 2023.
9. Circulating supply figure from DefiLlama stablecoin data, retrieved 21 August 2026.