Auditchain Policy | Regulatory Updates & Compliance

Policy agenda shines a light on blockchain structural disclosure with its focus on mining and validation.

Washington D. C. – May 14, 2026. Auditchain Labs AG submitted a comment letter to the FDIC in response to its Notice of Proposed Rulemaking implementing the GENIUS Act for FDIC-supervised permitted payment stablecoin issuers (PPSIs) and insured depository institutions (RIN 3064–AG19, 91 Fed. Reg. 18534).

Read the full comment letter here.

This is the latest in Auditchain’s coordinated series of submissions to the federal agencies responsible for GENIUS Act implementation—following the FDIC, OCC, NCUA, and SEC. Where the earlier FDIC submissions addressed application procedures, this NOPR governs the ongoing operational requirements PPSIs face once approved: reserves, capital, risk management, redemption, reporting, and supervision.

That makes it the right place to embed Blockchain Network Participation (BNP) disclosure directly into the framework that supervises issuers on a continuing basis.

The letter advances a single thesis: the GENIUS Act already requires this and well settled law requires it. Operational risk management, tailoring authority, and anti-evasion authority each demand the informational foundation that BNP disclosure provides. Structuring what is already required as a matter of well settled law—not requiring new disclosure.

Five recommendations:

Incorporate machine-readable BNP disclosure into proposed § 350.6, via a new § 350.6(c) plus six targeted amendments to existing subsections.
Require XBRL filing of all PPSI disclosures—weekly, monthly reserve composition, and quarterly—coordinated through the FFIEC.
Refine the yield-prohibition rebuttable presumption to rely on BNP disclosure as a fact-based enforcement mechanism rather than a broad presumption that may capture legitimate arrangements.
Adopt the BNP framework’s definitions for “distributed ledger” and “smart contract” through structured disclosure rather than static classification.
Coordinate with the OCC under the FFIEC so issuers file once, in one taxonomy, across both jurisdictions.

The framework itself is unchanged and incorporated by reference: seven disclosure categories, a 148-question questionnaire mapped to a 125-element XBRL taxonomy, with equal-input/equal-output validation that turns disclosure into an automated supervisory tool.

The counterfactual is the point: if every GENIUS Act regulator required disclosure in the same machine-readable taxonomy, interagency duplication—which the Act itself directs agencies to avoid would disappear by construction.

About Auditchain Labs AG

Auditchain Labs AG is a provider of global standards based regulatory disclosure automation and validation infrastructure. Pacioli.ai enables disclosure infrastructure and instance development as well as internal and external validation. Pacioli.ai enables organizations to prepare financial and non-financial disclosure models and export them in any data format, including XBRL and iXBRL, as required under capital markets legislation.

About Pacioli.ai

Pacioli.ai is the world’s first web3 and AI enabled regulatory disclosure automation infrastructure for crypto assets.