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Briefing special·Assets

Stablecoin issuer disclosure: what attestations, licences and white papers each prove

A monthly attestation, a MiCA EMT authorisation and a NYDFS trust charter are different documents. Treating them as one 'backed 1:1' fact is how files go wrong.

Published 25 Aug 2026/Updated 25 Aug 2026/12 min/Global

Stablecoins are the first digital-asset category that traditional financial institutions have had to file on at scale. That has improved the document set. It has also created a false sense of comparability. RCA's stablecoin desk reads four artefacts separately: the supervisory status of the issuing legal person; the disclosure document (white paper, terms, prospectus); the reserve or safeguarding evidence (attestation, audit, custodian report); and the holder-rights language, including redemption, insolvency and fork/upgrade control.

Four artefacts, four jobs

  • Licence or authorisation — proves the legal person is inside a named perimeter at a date. Does not prove reserve quality.
  • White paper / terms — proves what the issuer claims about the token. Does not prove the claim is currently true.
  • Attestation — proves an accountant performed specified procedures on a specified date. Does not prove a going-concern audit of the group.
  • Bank / custodian letters — prove a relationship existed when written. Do not prove bankruptcy remoteness.

On that split, Circle's EU EMT path, Paxos's NYDFS trust path, SG-FORGE's bank-affiliated EURCV path, Ripple's RLUSD path and Tether's attestation-led path are not the same evidence picture. RCA scores them on coverage, not on a preference for any ticker.

What this proves

Public documents now allow a differentiated evidence picture across major USD and EUR stablecoin issuers, including clear gaps where attestations stand in for authorisation or audit.

What it does not prove

A ranking of which stablecoin is 'safest' or a recommendation to hold, redeem or use any token.

RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.