{
  "schema": "cryptowhat/0.1",
  "site": "https://cryptowhat.net",
  "title": "Should your business accept stablecoins?",
  "brand": "Crypto What",
  "tagline": "Cryptocurrency, Gone Simple",
  "generated_at": "2026-09-25T12:26:01+00:00",
  "notice": "Crypto What publishes dated facts about accepting stablecoins, each one cited to a listed source. Anchoring proves a record existed on a date and has not been edited since; it says nothing about whether the content is correct. Nothing here is tax, legal, accounting or investment advice, and nothing here evaluates a specific business, token or counterparty.",
  "valid_as_of": "2026-09-23",
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    "ref": "rubric:2026-09-23",
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    "network": "eip155:84532",
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  "url": "https://cryptowhat.net/rubric.html",
  "sources": [
    {
      "n": 1,
      "label": "Stripe newsroom — Shopify and Stripe stablecoin payments (dated June 12, 2025)",
      "ref": "https://stripe.com/newsroom/news/shopify-stripe-stablecoin-payments",
      "date": "2026-09-07"
    },
    {
      "n": 2,
      "label": "Eco — how to accept stablecoins on Shopify, complete merchant guide 2026 (example of a rail-published guide)",
      "ref": "https://eco.com/support/en/articles/14895617-how-to-accept-stablecoins-on-shopify-complete-merchant-guide-2026",
      "date": "2026-08-24"
    },
    {
      "n": 3,
      "label": "JD Power Merchant Services Satisfaction Survey — 19% of US small businesses accept crypto, up 4 points year on year",
      "ref": "https://www.jdpower.com/business/press-releases/2026-us-merchant-services-satisfaction-study",
      "date": "2026-09-07"
    },
    {
      "n": 4,
      "label": "PayPal and National Cryptocurrency Association survey by The Harris Poll — fielded 2025-10-21 to 2025-10-27, published 2026-01-27; n=619 payment-strategy decision makers across four consumer-facing verticals (39% of US merchants; 34% of small businesses)",
      "ref": "https://newsroom.paypal-corp.com/2026-01-27-Crypto-Goes-Mainstream-4-in-10-US-Merchants-Accept-Digital-Assets",
      "date": "2026-09-07"
    },
    {
      "n": 5,
      "label": "Federal Register — FinCEN/OFAC proposal on permitted payment stablecoin issuer AML/CFT obligations",
      "ref": "https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism",
      "date": "2026-08-24"
    },
    {
      "n": 6,
      "label": "Federal Register — FDIC GENIUS Act proposed rule, published 2026-04-10, comments closed 2026-06-09",
      "ref": "https://www.federalregister.gov/documents/2026/04/10/2026-06974/genius-act-requirements-and-standards-for-fdic-supervised-permitted-payment-stablecoin-issuers-and",
      "date": "2026-09-07"
    },
    {
      "n": 7,
      "label": "FBI IC3 2025 Annual Report (crypto-linked fraud losses; complaint counts; kiosk complaints)",
      "ref": "https://www.ic3.gov/AnnualReport/Reports/2025_IC3Report.pdf",
      "date": "2026-08-24"
    },
    {
      "n": 8,
      "label": "Malwarebytes threat-intelligence post, August 2026",
      "ref": "https://www.malwarebytes.com/blog/threat-intel/2026/08/scammers-are-using-fake-crypto-aml-checkers-to-drain-your-wallet",
      "date": "2026-08-24"
    },
    {
      "n": 9,
      "label": "Latham & Watkins — US Crypto Policy Tracker, legislative developments",
      "ref": "https://www.lw.com/en/us-crypto-policy-tracker/legislative-developments",
      "date": "2026-09-07"
    },
    {
      "n": 10,
      "label": "ESMA guidelines on the assessment of knowledge and competence under MiCA Arts 68(5) and 81(7), dated 2026-01-28 (application date 2026-07-28 derived from the six-month rule)",
      "ref": "https://www.esma.europa.eu/sites/default/files/2026-01/ESMA35-24871704-2922_Guidelines_for_the_criteria_on_the_assessment_of_knowledge_and_competence_under_MiCA.pdf",
      "date": "2026-09-07"
    },
    {
      "n": 11,
      "label": "FDIC — notice of proposed rulemaking approved by the board 2026-04-07 (Financial Institution Letter)",
      "ref": "https://www.fdic.gov/news/financial-institution-letters/2026/notice-proposed-rulemaking-establish-genius-act",
      "date": "2026-09-07"
    },
    {
      "n": 12,
      "label": "Federal Register — Treasury GENIUS Act regulations, published 2026-08-18, comments due 2026-10-19",
      "ref": "https://www.federalregister.gov/documents/2026/08/18/2026-16796/genius-act-regulations-on-payment-stablecoin-issuance-offer-and-sale",
      "date": "2026-09-07"
    },
    {
      "n": 13,
      "label": "CoinDesk — US Senate opens first stage of CLARITY Act voting",
      "ref": "https://www.coindesk.com/policy/2026/08/08/u-s-senate-opens-first-stage-of-crypto-clarity-act-voting-to-give-bill-a-chance-next-month",
      "date": "2026-08-24"
    },
    {
      "n": 14,
      "label": "Troutman — Senate adjourns without CLARITY vote; September vote calendared",
      "ref": "https://www.troutmanfinancialservices.com/2026/08/senate-adjourns-without-clarity-act-vote-but-september-vote-now-on-the-calendar/",
      "date": "2026-09-07"
    },
    {
      "n": 15,
      "label": "This site — editorial record",
      "ref": "/about",
      "date": "2026-09-23"
    },
    {
      "n": 16,
      "label": "Stripe documentation — Stablecoin payments (payment-method properties, disputes, refunds, transaction limits)",
      "ref": "https://docs.stripe.com/payments/stablecoin-payments",
      "date": "2026-09-07"
    },
    {
      "n": 17,
      "label": "Stripe — published pricing page (stablecoins priced under Payments and again under Link)",
      "ref": "https://stripe.com/pricing",
      "date": "2026-09-07"
    },
    {
      "n": 18,
      "label": "GENIUS Act as enacted — Public Law 119-27 (S. 1582), approved July 18, 2025; section 20 is the effective-date section",
      "ref": "https://www.govinfo.gov/content/pkg/PLAW-119publ27/html/PLAW-119publ27.htm",
      "date": "2026-09-07"
    },
    {
      "n": 19,
      "label": "Federal Register — SEC proposed rule \"Regulation Crypto Assets\", published 2026-08-21, comments due 2026-10-20",
      "ref": "https://www.federalregister.gov/documents/2026/08/21/2026-17183/regulation-crypto-assets",
      "date": "2026-09-07"
    },
    {
      "n": 20,
      "label": "Federal Register — search over RULE documents for \"GENIUS Act\" (the search behind the no-final-rule reading)",
      "ref": "https://www.federalregister.gov/documents/search?conditions%5Bterm%5D=%22GENIUS+Act%22&conditions%5Btype%5D%5B%5D=RULE",
      "date": "2026-09-07"
    },
    {
      "n": 21,
      "label": "United States Senate — Tentative 2026 Legislative Schedule (state work period 2026-08-10 to 2026-09-11)",
      "ref": "https://www.senate.gov/legislative/2026_schedule.htm",
      "date": "2026-09-07"
    },
    {
      "n": 22,
      "label": "United States Senate — Roll Call Vote No. 234, 119th Congress, 2nd Session (2026-09-15) — cloture on the motion to proceed to H.R. 3633",
      "ref": "https://www.senate.gov/legislative/LIS/roll_call_votes/vote1192/vote_119_2_00234.htm",
      "date": "2026-09-23"
    }
  ],
  "criteria": [
    {
      "id": "C1",
      "title": "What you would actually be paid in, and where it lands",
      "question": "if a customer pays in a stablecoin, what arrives in your bank account, and when?",
      "facts": [
        "What to look at in your setup. Which processor you already use.",
        "Whether you want dollars in the account you have now, or the stablecoin itself.",
        "Which country you are in, and which countries your customers are in.",
        "What the published terms say, read 2026-09-07. These figures come from Stripe's own product documentation this edition, because the earlier edition took them from a newsroom post that did not carry most of them.",
        "Stripe lists customer locations as Global, excluding sanctioned countries; accepts USDC on the Tempo, Ethereum, Solana, Polygon and Base networks, with USDP and USDG in narrower US-only forms; presents prices in USD, with other currencies in private preview; and settles completed payments into your Stripe balance in your local currency.",
        "A single customer transaction is capped at 10,000 USD.",
        "On Stripe's published pricing page the same day, stablecoins are priced at 1.5% of the transaction amount in USD in the Payments block, and at 0.8% per successful transaction in the Link block, where that 0.8% is marked a promotional rate through January 1, 2027 with 0.2% added after that.",
        "Two prices on one page on one day is what the page says; which one applies to you is a question to put to the processor in writing.",
        "The earlier edition of this page said merchants could be paid in the stablecoin itself — that option is in the June 2025 announcement and is not in the current product documentation, so this edition does not claim it.",
        "Shopify, Coinbase and Stripe brought USDC checkout to merchants across 34 countries, announced June 2025.",
        "PayPal has its own stablecoin, PYUSD; this edition has not read PayPal's merchant terms and quotes no figures for it.",
        "When the answer is no. Your customers are in a country the processor excludes, or your ordinary order is larger than the per-transaction ceiling, or you want dollars at the end of it and the published rate is worse than the blended rate you actually pay on cards today — compare it against your real statement, not against the headline rate on anyone's pricing page."
      ],
      "sources": [
        {
          "n": 1,
          "label": "Stripe newsroom — Shopify and Stripe stablecoin payments (dated June 12, 2025)",
          "ref": "https://stripe.com/newsroom/news/shopify-stripe-stablecoin-payments",
          "date": "2026-09-07"
        },
        {
          "n": 16,
          "label": "Stripe documentation — Stablecoin payments (payment-method properties, disputes, refunds, transaction limits)",
          "ref": "https://docs.stripe.com/payments/stablecoin-payments",
          "date": "2026-09-07"
        },
        {
          "n": 17,
          "label": "Stripe — published pricing page (stablecoins priced under Payments and again under Link)",
          "ref": "https://stripe.com/pricing",
          "date": "2026-09-07"
        }
      ],
      "hand_back": null,
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
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    },
    {
      "id": "C2",
      "title": "Whether any of your customers would use it",
      "question": "do you have evidence that your own customers want to pay this way, or only evidence that some businesses accept it?",
      "facts": [
        "What to look at in your setup. Ask your staff whether anyone has requested it in the last year.",
        "Search your own inbox and your point-of-sale notes.",
        "Count.",
        "What the published numbers say. One survey — JD Power's merchant-services satisfaction survey — put 19% of US small businesses accepting crypto, up four points year on year.",
        "That is a single source and this edition has not read its method.",
        "A second, run by The Harris Poll for PayPal and the National Cryptocurrency Association, put small businesses at 34%; it was fielded 2025-10-21 to 2025-10-27 and published 2026-01-27, and its 619 respondents were payment-strategy decision makers in four consumer-facing industries rather than a general sample of small businesses.",
        "The four-in-ten figure quoted from it is all US merchants, not small ones, and PayPal sells the rail.",
        "Acceptance figures describe other businesses.",
        "None of them is evidence about your customers.",
        "Both were checked again on 2026-09-07 and both came back unchanged: the PayPal and Harris release still carries its figures, the same field window, the same 619 respondents and a stated precision of plus or minus 3.9 percentage points at 95% confidence; the JD Power release still carries the 19% sentence word for word, read through a reader proxy because jdpower.com refuses this site directly.",
        "When the answer is no. Nobody has asked, and you cannot name a customer or a segment who would use it.",
        "Acceptance costs you setup, reconciliation and a new failure mode.",
        "Demand you cannot name will not pay for that."
      ],
      "sources": [
        {
          "n": 3,
          "label": "JD Power Merchant Services Satisfaction Survey — 19% of US small businesses accept crypto, up 4 points year on year",
          "ref": "https://www.jdpower.com/business/press-releases/2026-us-merchant-services-satisfaction-study",
          "date": "2026-09-07"
        },
        {
          "n": 4,
          "label": "PayPal and National Cryptocurrency Association survey by The Harris Poll — fielded 2025-10-21 to 2025-10-27, published 2026-01-27; n=619 payment-strategy decision makers across four consumer-facing verticals (39% of US merchants; 34% of small businesses)",
          "ref": "https://newsroom.paypal-corp.com/2026-01-27-Crypto-Goes-Mainstream-4-in-10-US-Merchants-Accept-Digital-Assets",
          "date": "2026-09-07"
        }
      ],
      "hand_back": null,
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
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    },
    {
      "id": "C3",
      "title": "What happens when a payment goes wrong",
      "question": "after a payment is disputed, who can reverse it, on what grounds, within what window, and who ends up out of pocket?",
      "facts": [
        "What to look at in your setup. Your dispute rate on cards over the last twelve months.",
        "Whether you ship or deliver before a payment is confirmable.",
        "Whether you have ever had to reverse a payment yourself as a goodwill gesture.",
        "What one processor's published terms say, read 2026-09-07. Stripe's product documentation for stablecoin payments lists dispute support: no.",
        "Its own explanation is that the customer authenticates the payment with their bank, so — in its words — you won't have disputes that turn into chargebacks with funds withdrawn from your Stripe account.",
        "Refunds are supported, in full and in part, but a refund is always returned as stablecoins to the customer's original wallet, not as dollars to a card.",
        "On the same processor's published pricing, a dispute received on a card payment carries a $15.00 fee, and that is the comparison worth holding in your head: the card product has a dispute process with a price on it, and the stablecoin product has neither.",
        "What that means, and what it does not. It does not mean nothing can go wrong.",
        "It means the reversal mechanism you are used to is absent, so whatever recourse exists comes from your contract with the processor and from your own refund procedure rather than from a network's dispute rules.",
        "One processor's terms have now been read.",
        "No other processor's have. If you use a different one, find the dispute section of its terms and read it end to end; the asymmetry to confirm in writing is the same one.",
        "When the answer is no. Your dispute rate is high, or you release goods before delivery is confirmable, or your processor's terms carry no dispute process at all and you have nothing of your own to put in its place.",
        "Any of those makes the recourse gap the whole decision."
      ],
      "sources": [
        {
          "n": 16,
          "label": "Stripe documentation — Stablecoin payments (payment-method properties, disputes, refunds, transaction limits)",
          "ref": "https://docs.stripe.com/payments/stablecoin-payments",
          "date": "2026-09-07"
        },
        {
          "n": 17,
          "label": "Stripe — published pricing page (stablecoins priced under Payments and again under Link)",
          "ref": "https://stripe.com/pricing",
          "date": "2026-09-07"
        }
      ],
      "hand_back": null,
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
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        "note": "An anchor proves this record existed on this date and has not been edited since. It says nothing about whether the record is correct.",
        "ref": "rubric:C3",
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    },
    {
      "id": "C4",
      "title": "Bookkeeping and tax treatment",
      "question": "how does this appear in your books, and what does it change at year end?",
      "facts": [
        "What to look at in your setup. Who does your bookkeeping, what software they use, and whether that software already has a place to put a payment that arrives in something other than dollars.",
        "Whether your accountant has handled this for another client.",
        "When the answer is no. Your accountant has not done this before and does not want to learn it on your books.",
        "That is a real no, and it is cheaper than the alternative."
      ],
      "sources": [],
      "hand_back": "Here. Tax treatment and accounting treatment are a licensed accountant's work, and this site holds no accounting licence and gives no tax advice. Take these questions to your CPA before you turn anything on: how is each payment recorded at the moment it is received, what happens between receipt and settlement to dollars, what has to be tracked per transaction, what changes on the return, and what does the accountant need from the processor's reports to do the work without re-keying it.",
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
      "anchor": {
        "schema": "cryptowhat.anchor/0.1",
        "note": "An anchor proves this record existed on this date and has not been edited since. It says nothing about whether the record is correct.",
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    },
    {
      "id": "C5",
      "title": "Whether to hold any of it",
      "question": "settle everything to dollars, or keep a balance?",
      "facts": [
        "This rubric takes a position and it is a narrow one.",
        "It will not tell you whether to hold a stablecoin balance. What a business keeps on its balance sheet is investment-adviser territory, this site holds no licence, and a web page cannot know your cash position.",
        "What to look at in your setup. Whether you need every dollar of receipts for payroll and stock in the same month.",
        "Whether anyone in the business is authorised to make a treasury decision at all.",
        "The one position this page takes. A treasury decision made alone off a web page is the part of this that goes wrong.",
        "Including off this web page."
      ],
      "sources": [
        {
          "n": 1,
          "label": "Stripe newsroom — Shopify and Stripe stablecoin payments (dated June 12, 2025)",
          "ref": "https://stripe.com/newsroom/news/shopify-stripe-stablecoin-payments",
          "date": "2026-09-07"
        }
      ],
      "hand_back": "Take the holding question to a licensed adviser, together with your accountant. The processors named in criterion 1 publish an option to settle to a bank account in dollars, which is a fact about their product, not a suggestion about your business.",
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
      "anchor": {
        "schema": "cryptowhat.anchor/0.1",
        "note": "An anchor proves this record existed on this date and has not been edited since. It says nothing about whether the record is correct.",
        "ref": "rubric:C5",
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        "verify_url": "https://cryptowhat.net/verify/?ref=rubric:C5"
      }
    },
    {
      "id": "C6",
      "title": "Counterparty and processor risk",
      "question": "between your customer's payment and the money reaching your bank, who is holding it, and what happens if they stop?",
      "facts": [
        "What to look at in your setup. Get it in writing from the processor: who holds the funds at each step, under what agreement, and what the published procedure is if a payment is held or an account is paused.",
        "Ask what happens to funds in flight.",
        "What the record shows. A stablecoin's issuer can act at the token layer.",
        "Circle operates a freeze and blocklist capability on its own token, which this edition has from a secondary source rather than from Circle's own documentation.",
        "In April 2026 FinCEN and OFAC published a joint proposal on real-time sanctions screening in the Federal Register; by its terms it binds permitted payment stablecoin issuers, not the merchants who accept the tokens.",
        "When the answer is no. You cannot get the custody chain in writing.",
        "A verbal answer from a sales representative is not the answer to this question."
      ],
      "sources": [
        {
          "n": 5,
          "label": "Federal Register — FinCEN/OFAC proposal on permitted payment stablecoin issuer AML/CFT obligations",
          "ref": "https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism",
          "date": "2026-08-24"
        }
      ],
      "hand_back": null,
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
      "anchor": {
        "schema": "cryptowhat.anchor/0.1",
        "note": "An anchor proves this record existed on this date and has not been edited since. It says nothing about whether the record is correct.",
        "ref": "rubric:C6",
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    },
    {
      "id": "C7",
      "title": "Fraud, from the merchant's side of the counter",
      "question": "which of the ways this goes wrong are aimed at you rather than at the customer?",
      "facts": [
        "The procedure that matters most. Confirm receipt in your processor's dashboard, or on a block explorer, before you release goods.",
        "Never on the strength of a screenshot, an email, a text message or a phone call from the buyer.",
        "Make that a written rule for whoever is on the counter, because it is the one that will be tested.",
        "What the record shows. The FBI's IC3 reported 181,565 complaints and about $11.366 billion in crypto-linked fraud losses for 2025, with complaints from people aged 60 and over accounting for more than $7.7 billion, up 37% year on year.",
        "Crypto kiosk complaints came to 13,460 and about $389 million, up 58%.",
        "Address poisoning — a fraudulent address planted where a real one is expected — is a named pattern in public advisories.",
        "In August 2026 Malwarebytes reported that fake crypto checking tools are themselves being used to drain wallets, the same template rebranded under several names.",
        "That last one is the reason this site asks you to paste nothing anywhere: pasting an address into an unfamiliar tool is the attack.",
        "When the answer is no. Nobody in the business will own the confirm-before-release rule.",
        "Then this is a fraud loss waiting for a busy Saturday."
      ],
      "sources": [
        {
          "n": 7,
          "label": "FBI IC3 2025 Annual Report (crypto-linked fraud losses; complaint counts; kiosk complaints)",
          "ref": "https://www.ic3.gov/AnnualReport/Reports/2025_IC3Report.pdf",
          "date": "2026-08-24"
        },
        {
          "n": 8,
          "label": "Malwarebytes threat-intelligence post, August 2026",
          "ref": "https://www.malwarebytes.com/blog/threat-intel/2026/08/scammers-are-using-fake-crypto-aml-checkers-to-drain-your-wallet",
          "date": "2026-08-24"
        }
      ],
      "hand_back": null,
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
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        "schema": "cryptowhat.anchor/0.1",
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    },
    {
      "id": "C8",
      "title": "What the rules require now, and the dates that change it",
      "question": "is the rule you would be relying on actually in force?",
      "facts": [
        "What the record shows, read on 2026-09-07. The GENIUS Act was signed on 2025-07-18 and had not taken effect as of 2026-09-07.",
        "Section 20 of the statute — read this edition, not summarised from a tracker — says the Act takes effect on the earlier of 18 months after enactment, which is 2027-01-18, or 120 days after the primary Federal payment stablecoin regulators issue any final regulations implementing it.",
        "A Federal Register search over rule documents, run the same day, returns proposed rules and notices and no final rule from those regulators, so on that date the outer date was the operative one.",
        "Rulemaking was live at that reading, and a comment window is the part of it you can act on while it stands open: the FDIC board approved a proposed rule on 2026-04-07, it published on 2026-04-10 and its comment period closed on 2026-06-09; Treasury's proposal implementing section 3 published on 2026-08-18, with comments due by 2026-10-19.",
        "A separate SEC proposal, Regulation Crypto Assets, published on 2026-08-21 with comments due 2026-10-20; it governs offering and selling crypto assets as investments and does not govern a shop that accepts a dollar-denominated stablecoin in payment for goods.",
        "The CLARITY Act's cloture vote on the motion to proceed took place on 2026-09-15, the date the Senate's own tentative schedule pointed to once its state work period ran to 2026-09-11, and it failed: the Senate's own roll call record, Vote No.",
        "234, gives the result as 49 Yea to 50 Nay against the 60 votes needed to invoke cloture.",
        "The bill stayed on the Senate's calendar, and this page found no primary-source record of a rescheduled vote as of 2026-09-23.",
        "For readers in the EU: ESMA's knowledge-and-competence guidelines under MiCA Articles 68(5) and 81(7) ask crypto-asset service providers to review their staff's knowledge and competence at least once a year and to keep it current through continuous professional development or training.",
        "No external certification is mandated — the competence assessment may be run by the provider itself or by an external body — but a cadence is set: the guidelines tell providers to determine an adequate minimum number of hours of continuous professional development or training per year for the staff concerned, and the guidelines' own worked example for the least complex range of information is 10 hours, with 20 for staff giving advice.",
        "The earlier edition of this page said no cadence was set; re-reading the guidelines on 2026-09-07 showed that was wrong, and the Register carries the correction as its own dated entry.",
        "The obligation binds those providers rather than merchants.",
        "The guidelines are dated 2026-01-28 and apply six months after their publication on ESMA's website in all official EU languages, so the 2026-07-28 date is derived rather than printed in them, and it depends on when that all-languages publication actually happened.",
        "A limitation this edition closed, and one it still carries. The earlier edition read the effective-date rule from policy trackers rather than from the statute and said so on its face; the statute has now been read, and the trackers were right.",
        "Still carried, and stated rather than hidden: nobody here had read the Treasury or the SEC proposal in full — only their published dates, their dockets and their own abstracts of themselves.",
        "When the answer is no. You are in a regulated line of business where a rule change would force you to unwind the decision.",
        "Waiting until an effective date costs you nothing; rebuilding does."
      ],
      "sources": [
        {
          "n": 6,
          "label": "Federal Register — FDIC GENIUS Act proposed rule, published 2026-04-10, comments closed 2026-06-09",
          "ref": "https://www.federalregister.gov/documents/2026/04/10/2026-06974/genius-act-requirements-and-standards-for-fdic-supervised-permitted-payment-stablecoin-issuers-and",
          "date": "2026-09-07"
        },
        {
          "n": 10,
          "label": "ESMA guidelines on the assessment of knowledge and competence under MiCA Arts 68(5) and 81(7), dated 2026-01-28 (application date 2026-07-28 derived from the six-month rule)",
          "ref": "https://www.esma.europa.eu/sites/default/files/2026-01/ESMA35-24871704-2922_Guidelines_for_the_criteria_on_the_assessment_of_knowledge_and_competence_under_MiCA.pdf",
          "date": "2026-09-07"
        },
        {
          "n": 11,
          "label": "FDIC — notice of proposed rulemaking approved by the board 2026-04-07 (Financial Institution Letter)",
          "ref": "https://www.fdic.gov/news/financial-institution-letters/2026/notice-proposed-rulemaking-establish-genius-act",
          "date": "2026-09-07"
        },
        {
          "n": 12,
          "label": "Federal Register — Treasury GENIUS Act regulations, published 2026-08-18, comments due 2026-10-19",
          "ref": "https://www.federalregister.gov/documents/2026/08/18/2026-16796/genius-act-regulations-on-payment-stablecoin-issuance-offer-and-sale",
          "date": "2026-09-07"
        },
        {
          "n": 18,
          "label": "GENIUS Act as enacted — Public Law 119-27 (S. 1582), approved July 18, 2025; section 20 is the effective-date section",
          "ref": "https://www.govinfo.gov/content/pkg/PLAW-119publ27/html/PLAW-119publ27.htm",
          "date": "2026-09-07"
        },
        {
          "n": 19,
          "label": "Federal Register — SEC proposed rule \"Regulation Crypto Assets\", published 2026-08-21, comments due 2026-10-20",
          "ref": "https://www.federalregister.gov/documents/2026/08/21/2026-17183/regulation-crypto-assets",
          "date": "2026-09-07"
        },
        {
          "n": 20,
          "label": "Federal Register — search over RULE documents for \"GENIUS Act\" (the search behind the no-final-rule reading)",
          "ref": "https://www.federalregister.gov/documents/search?conditions%5Bterm%5D=%22GENIUS+Act%22&conditions%5Btype%5D%5B%5D=RULE",
          "date": "2026-09-07"
        },
        {
          "n": 21,
          "label": "United States Senate — Tentative 2026 Legislative Schedule (state work period 2026-08-10 to 2026-09-11)",
          "ref": "https://www.senate.gov/legislative/2026_schedule.htm",
          "date": "2026-09-07"
        },
        {
          "n": 22,
          "label": "United States Senate — Roll Call Vote No. 234, 119th Congress, 2nd Session (2026-09-15) — cloture on the motion to proceed to H.R. 3633",
          "ref": "https://www.senate.gov/legislative/LIS/roll_call_votes/vote1192/vote_119_2_00234.htm",
          "date": "2026-09-23"
        },
        {
          "n": 9,
          "label": "Latham & Watkins — US Crypto Policy Tracker, legislative developments",
          "ref": "https://www.lw.com/en/us-crypto-policy-tracker/legislative-developments",
          "date": "2026-09-07"
        }
      ],
      "hand_back": "Anything about how a rule applies to your specific business in your specific state is an attorney's question.",
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
      "anchor": {
        "schema": "cryptowhat.anchor/0.1",
        "note": "An anchor proves this record existed on this date and has not been edited since. It says nothing about whether the record is correct.",
        "ref": "rubric:C8",
        "root": null,
        "leaf": null,
        "proof": null,
        "network": "eip155:84532",
        "tx": null,
        "verify_url": "https://cryptowhat.net/verify/?ref=rubric:C8"
      }
    },
    {
      "id": "C9",
      "title": "What you tell the customer, before and after",
      "question": "what does your published refund policy say the day after you turn this on?",
      "facts": [
        "What to look at in your setup. Your current refund policy, your receipt template, and your order-confirmation email.",
        "Read them as though a payment had arrived in something other than dollars, and mark every sentence that stops being true.",
        "One published term to write into the policy. On the one processor whose terms this edition has read, a refund on a stablecoin payment is always returned as stablecoins to the customer's original wallet.",
        "A customer who paid in a stablecoin and expects dollars back is a complaint your current policy does not answer.",
        "What to write. How a refund is issued and in what, how long it takes, what a customer should do if a payment does not appear, and who they reach.",
        "Publish it before the first payment, not after the first complaint.",
        "The mistake this page expects. Turning this on with the refund policy you have today, unchanged.",
        "It was written for cards.",
        "When the answer is no. Nobody has time to rewrite the policy this month.",
        "Then nobody has time to accept stablecoins this month either."
      ],
      "sources": [
        {
          "n": 16,
          "label": "Stripe documentation — Stablecoin payments (payment-method properties, disputes, refunds, transaction limits)",
          "ref": "https://docs.stripe.com/payments/stablecoin-payments",
          "date": "2026-09-07"
        }
      ],
      "hand_back": null,
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
      "anchor": {
        "schema": "cryptowhat.anchor/0.1",
        "note": "An anchor proves this record existed on this date and has not been edited since. It says nothing about whether the record is correct.",
        "ref": "rubric:C9",
        "root": null,
        "leaf": null,
        "proof": null,
        "network": "eip155:84532",
        "tx": null,
        "verify_url": "https://cryptowhat.net/verify/?ref=rubric:C9"
      }
    },
    {
      "id": "C10",
      "title": "Staff and process readiness",
      "question": "who does the work on an ordinary Tuesday?",
      "facts": [
        "What to look at in your setup. Name the person who reconciles the payments, the person who answers the question at six in the evening, and the person who covers both when the first one is on holiday.",
        "Write down the steps they follow.",
        "If the steps live only in one person's head, that is the finding.",
        "When the answer is no. One person, no written procedure, no cover.",
        "Accepting a new payment method adds a reconciliation path and a support path.",
        "Both need an owner with a name."
      ],
      "sources": [],
      "hand_back": null,
      "valid_as_of": "2026-09-23",
      "stale": false,
      "stale_reason": "last checked 2026-09-23, 2 days ago; within the 90-day review window",
      "anchor": {
        "schema": "cryptowhat.anchor/0.1",
        "note": "An anchor proves this record existed on this date and has not been edited since. It says nothing about whether the record is correct.",
        "ref": "rubric:C10",
        "root": null,
        "leaf": null,
        "proof": null,
        "network": "eip155:84532",
        "tx": null,
        "verify_url": "https://cryptowhat.net/verify/?ref=rubric:C10"
      }
    }
  ]
}
