A stablecoin attestation is not an audit

Inherited archive entry · retained from the earlier edition. Its factual, legal and policy claims have not all been reverified for 19 September 2026. Research scope.

What the standard says an attestation is

Auditors do not only produce audits. The attestation standard AT Section 101 defines a separate category of engagement in which a practitioner 'is engaged to issue or does issue an examination, a review, or an agreed-upon procedures report on subject matter, or an assertion about the subject matter'. The standard carves this out from the statements on auditing standards that govern a financial-statement audit, and it allows three levels of work, examination, review, or agreed-upon procedures, each giving a different strength of conclusion. It also makes a technical point worth keeping: where the underlying facts depart from the stated criteria, the practitioner should ordinarily report on the subject matter itself, not merely on management's assertion about it.

How two stablecoin issuers describe their own reports

Circle's transparency page, as retrieved on 16 September 2026, states that 'a Big Four accounting firm provides monthly third-party assurance that the value of USDC reserves are greater than the amount of USDC in circulation', prepared 'according to attestation standards set out by the American Institute of Certified Public Accountants'. It separately names Deloitte and Touche as Circle's financial-statement auditor, a different engagement with a different scope. Tether's own announcement of a BDO report, dated 19 August 2022, uses the words 'attestation' and 'assurance opinion' throughout, cites the ISAE 3000R standard, and does not use the word 'audit'; it describes BDO confirming that Tether's consolidated assets exceeded its consolidated liabilities as of 30 June 2022.

The distinction that gets lost in headlines

An attestation examines management's own assertion, against agreed criteria, at a stated point in time. A full financial-statement audit tests the underlying accounting records and internal controls more broadly, and is the engagement most readers picture when they hear the word. Neither company's own materials claim to have delivered the broader kind for their reserves. That is not necessarily a concealment; both name their standard and their firm. But a monthly or quarterly attestation answers a narrower, more mechanical question, whether reserves exceeded the stated liability on this date, under this scope, than 'were the books audited', and the two words are not interchangeable even though both involve outside accountants.

Questions to carry forward

• Does the report name an examination, a review, or agreed-upon procedures, and which did the firm actually perform?
• Is the accounting firm's opinion about management's assertion, or about the reserve figures directly?
• Has the frequency or scope of the report changed between the version being cited and the one currently published?

Reading a transparency page well starts with the word before 'report'. Attestation and audit describe different work, and a document that never uses the second word has not claimed to have done it.