Public comments on digital asset disclosure infrastructure and specifications.
Auditchain Labs AG has an active policy agenda and is an active participant in the regulatory and standard setting processes that determine how disclosure requirements are designed and implemented. Our engagement spans US federal and international agencies, international standards bodies, and legislative processes.
The submissions below form a coordinated, cross-agency series across the U.S. regulators implementing the GENIUS Act, and extend internationally to the United Kingdom’s Financial Conduct Authority. Each US submission builds on our Blockchain Network Participation (BNP) disclosure taxonomy and treats every rulemaking as a simultaneous Financial Data Transparency Act (FDTA) compliance decision. They are listed by regulator, most recent first within each.
XBRL US — Digital Asset Working Group
Auditchain Labs AG is the founder of the XBRL US Digital Asset Working Group, (“DAWG”). The mission of the DAWG is to develop XBRL disclosure standards for digital assets and crypto-asset issuers operating under the GENIUS Act and CLARITY Act.
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Federal Deposit Insurance Company
Comments across two FDIC proceedings: the proposed application requirements for issuance of payment stablecoins by subsidiaries of FDIC-supervised institutions (RIN 3064-AG20, proposed 12 CFR § 303.252) — where the BNP disclosure framework was first recommended — and the proposed ongoing requirements and standards that govern FDIC-supervised permitted payment stablecoin issuers after approval (RIN 3064-AG19).
FDIC Comment Letter — RIN 3064-AG20
Auditchain submitted a formal comment letter to the FDIC urging the agency to require XBRL-structured disclosures for stablecoin issuers — covering reserve composition, Blockchain Network Participation activities, and Legal Entity Identifier (LEI) identification.
Supplemental Comment RIN 3064-AG20— BNP Framework Expansion
Updated the BNP disclosure exhibits to add a seventh category covering non-affiliate third-party service provider arrangements, extending the taxonomy from 107 to 125 elements and the disclosure questionnaire from 136 to 148 questions across eight sections. The supplemental introduced the framework’s equal-input / equal-output validation architecture — a strict one-to-one correspondence between every disclosure question range and a single XBRL concept — so that omissions are programmatically detectable. This directly implements the GENIUS Act’s anti-evasion mandate under 12 U.S.C. § 5903(h)(1) and supports the FDIC’s examination authority under § 5905(a)(3). This is the authoritative current version of the BNP framework, incorporated by reference in our later filings.
SEC Regulation S-K Reform
Auditchain submitted comments to the SEC on Regulation S-K reform, proposing structured data modernization and a digital asset disclosure framework that aligns with XBRL standards already used across SEC filings.
GENIUS Act & MiCAR
We advocate for XBRL-based structured disclosure requirements under the GENIUS Act for stablecoins, and support MiCAR compliance through our MiCAR white paper automation platform.