Auditchain Labs Submits Comment Letter to FDIC Urging Structured Proof of Work and Proof of Stake Activity Disclosures for Stablecoin Applications

New York, New York – February 9, 2026 – Auditchain Labs AG, a provider of AI regulatory disclosure automation infrastructure today submitted a detailed comment letter to the Federal Deposit Insurance Corporation (FDIC) in response to the agency’s Notice of Proposed Rulemaking on approval requirements for the issuance of payment stablecoins by subsidiaries of FDIC-supervised institutions.

The submission is available under Regulatory Information Number (RIN) 3064-AG20, and focuses on strengthening the application process by incorporating comprehensive disclosures related to blockchain network participation (BNP) activities in a provable manner using open data standards.

The comment letter urges the FDIC to treat BNP—such as mining (Proof of Work), validation (Proof of Stake), and Blockchain-as-a-Service—as a core element of the application. It aligns these disclosures with the FDIC’s existing expectations for describing “related activities of the applicant,” which include operations at the applicant, subsidiary, and third-party levels.

The submission emphasizes that detailed information on BNP would enable more effective assessments of safety and soundness, particularly given the shared public infrastructure of blockchains and associated risks like external attacks, transaction dependencies on unknown third parties, and potential conflicts.

Key recommendations include:

Requiring applicants to provide initial and ongoing disclosures on BNP in a machine-readable, structured XBRL format to facilitate automated analysis and reduce regulatory burden.

Adding specific requirements for detailed policies and procedures governing BNP, including governance, risk management (e.g., mitigation of maximum extractable value or MEV risks through tools like Proposer-Builder Separation and private mempools), operational resilience, and compliance.

Mandating interim event-driven disclosures for BNP changes, such as shifts in hash rate, staked value, or third-party relationships.

The letter includes three exhibits: a comprehensive Blockchain Network Participation Disclosure Questionnaire (Exhibit A), a draft sample taxonomy for disclosures (Exhibit B), and type extensions specifications (Exhibit C), to support standardized reporting.

The submission directly addresses a practical gap in the proposed rule by advocating for explicit integration of BNP details into the “Contents of Filing” and requirements for ongoing disclosure.

By tying BNP to the FDIC’s framework for “related activities” and “proposed incidental activities” (such as MEV mitigation tools that support fair transaction ordering and network stability), the comment aims to balance safety and soundness and public trust.

The push for XBRL-based reporting could streamline supervisory reviews, promote consistency across applicants, and better equip the FDIC to evaluate risks inherent to public blockchains without imposing excessive burdens.

If incorporated, these changes would support a more transparent and efficient approval process for bank-issued stablecoins, aligning with the GENIUS Act’s goals of fostering innovation under strong oversight.

The extended comment period (now through May 18, 2026) provides additional opportunity for stakeholder input on these and related proposals.

About Auditchain Labs AG

Auditchain Labs AG is a pioneering force in developing web3 and artificial intelligence-based financial reporting, crypto-asset disclosure, and analysis applications and standards. With a commitment to transparency and accuracy, Auditchain Labs AG aims to revolutionize the landscape of financial and crypto-asset disclosure.

About Pacioli.ai

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