Using Regulated Stablecoins for Corporate Treasury: A Practical Assessment

The Corporate Treasury Question

The question of whether regulated stablecoins belong in a corporate treasury policy is being asked with increasing frequency by CFOs at fintech and technology companies with international operations. The framing is understandable: the promise of 24/7 settlement without correspondent banking friction, combined with the prospect of FCA authorisation providing a regulated counterpart to unregulated alternatives, makes stablecoins sound like a plausible addition to the treasury toolkit.

The reality, as of July 2025, is more cautious. The regulatory framework for FCA-authorised stablecoins is in consultation under CP25/14 and the authorisation gateway does not open until September 2026. The accounting treatment under IFRS for stablecoin holdings carries important conditions that most currently available stablecoins do not meet. And the operational risks of placing corporate cash in any digital asset instrument are not trivial.

This article aims to give corporate treasurers and CFOs a balanced, realistic framework for thinking about stablecoins in the treasury context, without either dismissing the use case or overstating the current readiness of the market.

The Genuine Use Cases

There are specific treasury use cases where FCA-authorised stablecoins would offer genuine advantages over the existing infrastructure. These are not speculative; they reflect real limitations in the current system that stablecoins are structurally better positioned to address.

24/7 cross-border payment settlement

The most compelling use case is cross-border payment settlement outside banking hours. The current correspondent banking system operates during business hours in the relevant jurisdictions and has cut-off times that can delay same-day settlement by 24 hours or more. For a company making regular cross-border payments (payroll in multiple jurisdictions, supplier payments in non-GBP currencies, intercompany transfers), the settlement delay and the associated FX exposure during that window is a genuine operational cost. An FCA-authorised GBP stablecoin used for UK-denominated intercompany or supplier payments would, in principle, enable T+0 settlement at any time of day or night.

Programmable payment logic

Stablecoins on programmable blockchains enable conditional payment execution through smart contracts. For specific corporate use cases (escrow arrangements with defined release conditions, milestone-based supplier payments, revenue sharing arrangements), smart contract payment logic removes the need for a trusted intermediary to hold and release funds and reduces the administrative overhead of managing conditional payment terms.

Potential yield on regulated stablecoins

It is important to be clear on this point: yield pass-through is currently prohibited under CP25/14. FCA-authorised stablecoin issuers are explicitly not permitted to pass interest earned on backing assets to token holders. The stablecoin must function as a money-like instrument, not a fixed-income product. Any adviser who suggests that stablecoin yields are a near-term treasury opportunity is either not current on CP25/14 or is conflating regulated stablecoins with unregulated alternatives. The yield stays with the issuer.

The Risks That Keep Most Treasury Teams Cautious

The risks of corporate stablecoin use in 2025 are substantial. A well-run corporate treasury function exists to protect the company's liquidity position, not to take unnecessary risks with operating cash. The following risks explain why most experienced treasury teams are watching the market rather than deploying.

• Regulatory uncertainty pre-September 2026: There are no FCA-authorised stablecoins as at July 2025. The authorisation gateway does not open until September 2026, and the first authorisations will take time after that. Any stablecoin currently marketed to corporate treasurers is operating outside the forthcoming authorised framework. Using an unauthorised stablecoin for corporate cash management introduces regulatory and reputational risk that is difficult to justify to a board.
• Counterparty risk on the issuer: Even a well-run stablecoin issuer has a balance sheet with counterparty risks embedded within it. The backing assets are held at custodians and in government securities, but the issuer itself can fail, and the insolvency resolution process for a stablecoin issuer is not as well-tested as for a bank. FCA authorisation mitigates this risk materially (through the statutory trust over backing assets), but the risk is not zero.
• Technology risk: Corporate cash held in stablecoins is subject to the technology risk of the blockchain infrastructure, the smart contracts involved in any programmatic operations, and the digital custody arrangements. A technology failure that prevents access to corporate cash for even 24 to 48 hours is operationally unacceptable for most businesses.
• FX risk on non-GBP stablecoins: A company that holds USD stablecoins for USD settlement purposes has a USD/GBP exposure on its treasury balance sheet. This is manageable with proper hedging, but it adds a layer of complexity that most treasury policies do not currently accommodate. GBP stablecoins eliminate this issue for GBP-denominated flows but create a different question: why not use a bank current account?
• Accounting treatment uncertainty for non-authorised stablecoins: See the accounting section below. The accounting treatment for stablecoins that do not meet the IAS 7 criteria for cash equivalents is materially less favourable, and most currently available stablecoins do not meet those criteria.

Accounting Treatment Under IFRS

The accounting treatment of corporate stablecoin holdings under IFRS is one of the most frequently misunderstood aspects of this topic. The treatment depends critically on whether the stablecoin meets the definition of cash or a cash equivalent under IAS 7, and that determination is fact-specific.

IAS 7 cash equivalent criteria

Under IAS 7, a cash equivalent must satisfy three criteria: it must be convertible to a known amount of cash, it must have a short maturity (generally three months or less from the date of acquisition), and it must be subject to an insignificant risk of change in value. For an FCA-authorised GBP stablecoin with a 1:1 backing pool, statutory trust protections, and mandatory T+1 redemption rights, the case for meeting all three criteria is strong. The amount is known (1 GBP per token), the liquidity is high (T+1 redemption), and the value risk is minimal (backed 1:1 by GBP-denominated assets under a statutory trust).

For an offshore, non-authorised stablecoin without equivalent protections, the position is very different. Such a stablecoin is most likely classified as an intangible asset under IAS 38 and measured at cost less any impairment. It sits outside the cash and cash equivalents line on the balance sheet, it cannot be treated as a liquid asset for covenant purposes unless the covenant specifically allows it, and any loss of peg (which has occurred with well-known stablecoins in the past) results in an immediate impairment charge through the P&L.

The practical consequence of this accounting distinction is significant. A company's liquidity ratios, covenant compliance, and investor communications all depend on the cash and cash equivalents line being accurately stated. Holding stablecoins that are classified as intangible assets but being treated operationally as cash is an accounting error that will be identified in the audit.

A Framework for the Treasury Policy Decision

Given the genuine use cases and the genuine risks, how should a CFO approach the question of whether stablecoins belong in the corporate treasury policy? The following framework is practical and proportionate:

1. Define the specific use case first. Do not start from "we should look at stablecoins"; start from a specific operational problem (e.g. "we are paying a supplier in Singapore at 10pm UK time and the payment arrives the next day"). The stablecoin use case must solve a specific, quantified problem to be worth the complexity it introduces.
2. Wait for authorised issuers post-September 2026 for any cash equivalent treatment. The accounting and regulatory framework for FCA-authorised stablecoins will be substantially clearer after the authorisation gateway opens and the first issuers are authorised. Deploying corporate cash into non-authorised instruments before that point introduces risks that are difficult to justify in a treasury policy.
3. Cap any exposure as a percentage of total liquid assets. Even after authorisation, stablecoins should not represent a material proportion of corporate cash. A cap of 5 to 10% of liquid assets in any novel instrument is a reasonable starting point for a treasury policy, with board approval required to exceed it.
4. Require board-approved treasury policy amendment. Any use of stablecoins for corporate treasury purposes should require an explicit amendment to the board-approved treasury policy, including the accounting treatment, the counterparty limits, and the operational risk controls.
5. Consult auditors before deployment. Agree the accounting treatment with your external auditors before deploying any stablecoin in the treasury. A post-hoc accounting restatement is an avoidable cost.

Key Takeaways

• The genuine use cases for regulated stablecoins in corporate treasury are 24/7 cross-border payment settlement and programmable payment logic for conditional payments. Yield generation is not a near-term use case under CP25/14.
• The risks that keep most treasury teams cautious are regulatory uncertainty (no FCA-authorised stablecoins exist yet), counterparty risk on the issuer, technology risk, and FX risk on non-GBP instruments.
• FCA-authorised GBP stablecoins are likely to qualify as cash equivalents under IAS 7 after the authorisation gateway opens. Non-authorised or offshore stablecoins are intangible assets at cost less impairment.
• The accounting treatment is binary and consequential: cash equivalents sit on the cash line and support liquidity ratios; intangible assets do not.
• A responsible treasury policy approach involves defining the specific use case, waiting for authorised issuers, capping exposure, obtaining board approval, and agreeing accounting treatment with auditors in advance.
• The appropriate posture for most corporate treasury functions in mid-2025 is informed monitoring, not active deployment.