StableCheck: Lessons for Issuers and Partners

In October 2025, the Stablecoin Standard published StableCheck, a due diligence methodology designed to help participants navigate the rapid growth of stablecoins globally. Since then, demand for the StableCheck framework has grown steadily, and we have seen its approach adopted and adapted in both public and private sector efforts toward responsible innovation in the stablecoin sector.

The StableCheck methodology is useful for anyone evaluating payment stablecoins, DeFi stablecoins, or other digital money products. It is grounded in three pillars of the Stablecoin Standard framework, announced in 2025 and 2026, and aligned with global regulatory, legal, and policy expectations for operational resilience, consumer protection, and sound financial and product design.

The StableCheck Working Group has spent the past several months applying the due diligence process in practice, stress-testing its assumptions and refining its approach. As the CLARITY Act moves forward, implementing regulations take shape globally, and discussions around agentic payments accelerate, we are pleased to share what we have learned. These developments make the StableCheck methodology more relevant than ever.

Five Lessons from the StableCheck Process

Lesson 1: StableCheck surfaces what disclosures alone cannot.

StableCheck provides a practical foundation for testing the claims made by stablecoin issuers and identifying gaps in participants' risk controls. The due diligence process surfaces questions that disclosures alone do not always answer.

In practice, issuers across all market cap tiers, from early-stage entrants to the largest USD-denominated stablecoins, have found that the StableCheck process prompts a closer examination of their own operations. Publicly available documentation often presents an optimistic picture. StableCheck's structured review across the Six Pillars covering reserve quality, redemption reliability, governance, transparency, on-chain performance, and cyber resilience creates a consistent framework for pressure-testing those claims.

This is particularly important in the current environment. As regulators in the United States, European Union, United Kingdom, Hong Kong, and other jurisdictions develop and refine their frameworks, the gap between what issuers say and what they can demonstrate is a meaningful area of risk. The due diligence process does not replace regulatory supervision, but it can complement it. Institutions evaluating stablecoin partners whether for payments, treasury management, or DeFi deployment benefit from a structured way to probe issuer claims about reserve composition, redemption capacity, and legal segregation. The process helps turn disclosure documents into a dialogue.

One consistent finding: governance and risk management disclosures are often less developed than reserve and redemption disclosures. Smaller and newer issuers, in particular, may meet reserve requirements while having limited visibility into board oversight, risk committee structures, or conflict-of-interest policies. StableCheck's approach to the Regulatory Oversight & Governance pillar has helped surface these gaps and provided a roadmap for issuers to address them.

Lesson 2: The scoring framework is designed to level the playing field - but scoring across geographies requires care.

StableCheck was built for simplicity in a complex and fast-moving sector. The scoring framework accounts for market dynamics, supporting both new issuers competing for USD market share and established industry leaders on equal terms.

That commitment to fairness requires careful attention to how market size and geography interact with scoring. The stablecoin market remains highly concentrated: a small number of USD-denominated stablecoins account for the vast majority of total value locked (TVL) and on-chain transaction volume. Any scoring framework that treats market cap as a proxy for quality risks entrenching incumbents and disadvantaging newer or smaller issuers — particularly those operating under strong regulatory frameworks in jurisdictions outside the United States.

Geography adds a further layer of complexity. Stablecoins operate under materially different regulatory regimes depending on jurisdiction. An issuer licensed as an Electronic Money Institution under MiCA in the European Union, a trust company under a New York State charter, and an entity holding a Major Payment Institution licence in Singapore may all meet their local requirements but those requirements are not identical, and they do not map onto StableCheck's criteria in exactly the same way. Regulatory equivalence is an open question in many jurisdictions, and some regulatory regimes impose requirements (such as mandatory reserve insurance or real-time reporting) that others do not.

Lesson 3: The process is iterative - and the first score is only the beginning.

The process is designed to be iterative. An initial provisional score is meant to be revisited, setting goals for continuous improvement rather than delivering a one-time verdict.

This design principle has proven valuable in practice. The StableCheck Working Group has observed that issuers often make material improvements to their disclosures, governance structures, and risk management practices as a direct result of engaging with the due diligence process. This is consistent with StableCheck's purpose: not to rank stablecoins against each other, but to provide each issuer with a clear picture of where it stands relative to defined standards and what concrete steps would improve its position.

For issuers, the practical implication is that a provisional score is a starting point, not a ceiling. The StableCheck methodology includes explicit "level-up pathways": for each indicator where an issuer receives partial credit or no credit, there is a defined action that would move the score. An issuer receiving a 0.5 on reserve asset valuation - because it marks reserves to market weekly rather than daily has a clear path to a 1. An issuer that has not yet completed an independent annual audit knows exactly what it needs to do to close that gap. This structure transforms the scoring process into a planning tool.

Lesson 4: StableCheck is a tool for industry development, not just assessment.

StableCheck scores serve as a tool for industry development, helping issuers strengthen their risk management practices and refine their growth strategies over time.

This lesson has emerged most clearly in conversations with issuers who have engaged deeply with the process. The StableCheck framework provides something that few other tools in the stablecoin sector currently offer: a structured, evidence-based reflection on an issuer's own practices compared to a globally consistent benchmark. For issuers at earlier stages of development, this can surface risks they had not fully considered around legal segregation of reserves, stress testing procedures, or the robustness of contingency plans. For more mature issuers, it provides a framework for communicating the strength of their practices to institutional partners and regulators.

Lesson 5: StableCheck is aligned with — and designed to evolve alongside - the emerging regulatory landscape.

StableCheck is aligned with emerging regulatory and market trends for payment stablecoins. We remain committed to supporting the due diligence process as a way to manage uncertainty in the market while the stablecoin ecosystem and the Stablecoin Standard community continue to evolve.

The convergence of regulatory activity across major jurisdictions has been striking. The CLARITY Act in the United States, the MiCA framework in the European Union, the UK's Payment Services legislation, and Singapore's Payment Services Act all represent serious attempts to bring stablecoin issuance within a regulated framework. Each regime has distinctive features different reserve requirements, different redemption timelines, different approaches to cross-border issuance but they share a common set of underlying concerns: reserve quality, redemption reliability, consumer protection, and anti-money laundering compliance. These are precisely the areas that StableCheck's Six Pillars were designed to assess.

This alignment is not coincidental. The Stablecoin Standard has been an active participant in regulatory consultations and industry roundtables across multiple jurisdictions, and the StableCheck methodology has been shaped by those discussions.

Looking ahead, two developments stand out as particularly significant. First, the growth of agentic payments in which AI systems make autonomous payment decisions on behalf of users raises new questions about the role of stablecoins in automated financial infrastructure. The risk management and transparency requirements for stablecoins operating in agentic contexts may differ from those applicable to traditional retail or institutional use cases, and StableCheck's framework will need to evolve to address this.

Second, the broader question of global regulatory harmonisation remains unresolved. The StableCheck methodology identifies harmonisation as a critical issue, and the Working Group remains committed to supporting efforts to develop common baseline standards not because all jurisdictions should have identical rules, but because material divergences create opportunities for regulatory arbitrage that ultimately undermine market integrity and consumer protection.

As far as the StableCheck committee using the StableCheck methodology to proactively score issuers is concerned, after much deliberation the decision has been made that it would not be appropriate to do so. Stablecoin Standard’s role as an industry body is to create best practices with our members, for our members, and then to support them to meet those standards. With the global playing field not being level, we will instead prioritize frequency of iteration of the StableCheck methodology between industry and policymakers, and working closely with both to ensure that the methodology continues to influence new regulations globally.

Many people contributed to StableCheck as a piece of work, and without them, StableCheck would simply not have been possible. We’d especially like to thank Alexander Maron, Lesley Chavkin, Rohit Sabhlok, Prabhjot Bajwa, Kenny Chan, Beth Haddock and Douglas Coburn for all their hard work over the past few months in stress testing and applying the methodology to reach these conclusions, as well as Monica Ramirez de Arellano & the original StableCheck task force. The methodology has influenced policies in both private sector and public sector alike, and will continue to be iterated upon to ensure Stablecoin Standard members contribute to future regulatory frameworks.