Opening the Door for Publicly Listed Companies? A Cheat Sheet for the Stock Exchange’s Stablecoin Accounting and Cryptocurrency Internal Control Guidelines

Summary of the key points from the "Guidelines for Stablecoin Transaction Accounting Treatment" and "Internal Control System for Cryptocurrency Holdings" issued by the Taiwan Stock Exchange and the Taipei Exchange. How do these guidelines help listed companies establish clear accounting and internal control standards when holding cryptocurrencies and stablecoins?

On May 29, 2026, the Taiwan Stock Exchange (TWSE) and the Taipei Exchange (TPEx) jointly issued the "Guidelines for Stablecoin Transaction Accounting Treatment" and the "Internal Control System for Cryptocurrency Holdings," to assist listed companies in establishing clear accounting and internal control standards for holding cryptocurrencies and stablecoins.

These two guidelines were developed jointly by the TWSE, TPEx, and the "Accounting Research and Development Foundation," marking the first comprehensive institutional framework in Taiwan's capital market for listed companies holding cryptocurrencies.

Stablecoin Accounting Treatment Guidelines: Three Classification Paths for USDC and USDT

The "Guidelines for Stablecoin Transaction Accounting Treatment" are based on the most common market transaction patterns of USDC and USDT, with four practical case studies. They explicitly state that companies cannot uniformly classify stablecoins; instead, classification must be based on the "current regulations" and the "latest user terms published by the stablecoin issuer" as the basis for accounting classification.

The key determinant is whether the holder has a "contractual right to receive cash or other financial assets." Based on this, the stablecoins held by companies will be classified into one of the following three categories:

• 1. Financial Assets: When the contractual terms explicitly grant the holder the right to redeem for cash.
• 2. Intangible Assets: When the stablecoin does not have a clear right to redeem for cash and is held for purposes other than sale.
• 3. Inventory: When the company holds stablecoins for sale or trading purposes.

Internal Control Guidelines: Hot wallets must not exceed 15%, custody requires SOC 1 Type 2 report

The "Internal Control System for Cryptocurrency Holdings" requires listed companies to establish internal controls across four areas: "Management of Cryptocurrency Holdings," "Creation of Virtual Wallets and Cryptocurrency Custody," "Acquisition, Disposition, Conversion, and Transfer," and "Cryptocurrency Payment and Receipt Transactions." It provides eight sample forms, including record books, virtual wallet assessment forms, transaction logs, and authority change request forms.

Core control requirements include:

1. The company must establish a "Cryptocurrency Management Unit," staffed with at least one cryptocurrency specialist and one cybersecurity officer, overseen by the board of directors. A three-tier approval structure (responsible manager → general manager → chairman) covers all major transactions.

2. Wallet management must implement multi-signature mechanisms, with initiators and approvers being different individuals. Private keys, seed phrases, and passwords must be stored separately, preventing any single person from independent access. The hot wallet's value must not exceed 15% of the total holdings; if exceeded, assets must be reallocated within five working days to cold wallets or third-party custody.

3. If third-party custody is used, the company should select an institution licensed locally for cryptocurrency services and obtain SOC 1 Type 2 or ISAE 3402 Type 2 system and organizational control reports, with annual reassessment of the custodian's compliance. The guidelines also recommend evaluating professional liability insurance, cybersecurity incident insurance, or digital asset insurance to cover losses caused by hacking, internal fraud, or system errors affecting hot/cold wallet assets.

4. All acquisition, disposition, conversion, or transfer transactions must be approved via application forms, authorized by responsible managers before execution, with the application valid for seven working days. Wallet addresses must be whitelisted before use.

Aligning with International Virtual Asset Regulations

The TWSE states that these guidelines aim to "align with international virtual asset regulatory trends" and assist listed companies in "practically operating smoothly in the Web3 era." They also connect with existing regulations such as the "Guidelines for Public Companies' Asset Acquisition and Disposition" and the procedures for major information disclosures by TWSE and TPEx. Cryptocurrency acquisitions or dispositions that meet certain thresholds still require public announcement and reporting.

These two guidelines focus on "enhancing information transparency and risk management," and are expected to become a standard reference framework for Taiwanese listed companies to establish their cryptocurrency asset holding systems in the future.

• This article is reprinted with permission from: "Chain News"
• Original title: "TWSE Releases Two Cryptocurrency Guidelines: Hot Wallets Not to Exceed 15%, USDC/USDT to Be Recognized in Accounting"
• Original author: Elponcrab