3. Reserve attestation cadence
A senior treasury reader will ask the next question immediately: how often does the issuer prove the reserves are there, and who is doing the proving. The answer separates issuers more cleanly than reserve composition does, because composition is a snapshot and cadence is the operating discipline around it.
First, the vocabulary. An attestation is an independent accountant's report on the composition of reserves at a point in time, performed under attestation standards rather than auditing standards. A financial statement audit is a different exercise: an external auditor opining on the issuer's full financial statements under Public Company Accounting Oversight Board (PCAOB) standards in the US, or the equivalent national framework elsewhere. Most major payment stablecoin issuers publish attestations, not audits. Treating the two as equivalent in a memo to a CFO is a fast way to lose credibility.
Market practice in 2026: USDC publishes monthly attestations from major audit firms, with a multi-year history of monthly cadence. USDT has historically published attestations on a less frequent cadence and in shorter form, with the methodology and the firms involved a recurring point of debate. A growing cohort of newer issuers publish on-chain near-real-time reserve composition feeds alongside the periodic attestation, sometimes with third-party verification of the data feed itself. The on-chain models are not a substitute for an attestation, but they materially shorten the gap between snapshots.
Why a treasury reader cares: most institutional investment policies require a minimum attestation cadence before a cash-equivalent instrument can be added to the approved list. Monthly is the modal floor. Some custodians and asset managers require daily reporting, which constrains the issuer set sharply. Without a satisfactory cadence the instrument cannot be allocated to, full stop, regardless of the headline reserve composition.
The major regimes have moved in the same direction. MiCA requires monthly reserve reporting for e-money token (EMT) and asset-referenced token (ART) issuers. The Hong Kong Stablecoins Ordinance imposes monthly attestation as a minimum for licensed issuers. The US GENIUS Act framework specifies monthly attestation for permitted payment stablecoin issuers. Japan's Payment Services Act (PSA) trust-issuance route requires the trust to disclose reserve composition to beneficiaries on a defined cadence. Monthly is the regulatory floor across the major perimeters; the differentiator is whether the issuer goes meaningfully beyond it.
Attestation cadence is the fourth of the four operational facts that distinguish payment stablecoin issuers in practice, alongside reserve composition, redemption policy, and depeg history. The other three appear elsewhere in this chapter; this is the one to add to the comparison grid.
4. Asset-referenced tokens (ART under MiCA)
The second flavour exists because MiCA built a category for instruments that reference more than one currency, or a basket of currencies and other assets, or commodities. These are asset-referenced tokens (ARTs). The classic example is a stablecoin that references a basket like Special Drawing Rights (SDR) weights, or a token backed by a mix of fiat and gold.
The category is interesting precisely because it was designed to fail the e-money test. Under EU law, e-money is electronically stored monetary value representing a claim on the issuer, denominated in a single fiat currency, issued on receipt of funds, and redeemable at par. A multi-currency basket fails the single-currency leg. So the EU created ART as a parallel regime, with its own authorisation, reserve, and disclosure requirements, sitting under MiCA Title III complementing the EMT regime in Title IV.
ART issuers must be authorised credit institutions or specifically authorised ART issuers. The reserve must be sufficient to cover liabilities and must be invested in highly liquid assets with minimal market and credit risk. ART holders have a redemption right, but the right is to the value of the referenced basket, not necessarily to a specific currency. Significant ARTs face the heaviest regime: caps on use as a means of exchange, additional capital requirements, recovery and redemption planning, and European Banking Authority (EBA) -level supervision.
In practice, ARTs are rare in production today. The economics are harder than payment stablecoins because the reference basket has to be tracked, the foreign exchange (FX) exposure has to be hedged or passed through, and the holder rarely wants basket exposure when they could just hold dollars. ARTs matter conceptually because they show how regulators carve up the design space: same chart shape as a payment stablecoin, completely different regime, completely different role.
For a TradFi institution, the ART category is most relevant when thinking about commodity-referenced tokens, cross-border settlement instruments referencing a basket, or any product where the reference is not a single fiat currency. Calling that thing a "stablecoin" in a memo to compliance will earn you a long meeting.