April 14, 2026 – Washington DC. In its April 2026 comment letter submitted to the National Credit Union Administration (NCUA) under Docket ID NCUA-2025-1335-0034, Auditchain Labs AG urges the agency to integrate comprehensive Blockchain Network Participation (BNP) disclosures into its rulemaking on investments in and licensing of permitted payment stablecoin issuers. Aligned with similar submissions to the FDIC and SEC, the proposal leverages structured, machine-readable data standards to address critical gaps in regulatory visibility of a new category of material information. By requiring detailed reporting on on-chain activities, the framework aims to enhance safety and soundness assessments, mitigate conflicts of interest, detect systemic risks, and enable scalable, technology-native supervision — all while minimizing compliance burdens for credit unions and their subsidiaries.
Blockchain Network Participation (BNP) encompasses a range of activities that stablecoin issuers and their affiliates may undertake on shared public blockchain networks. These include Proof-of-Work (PoW) mining, Proof-of-Stake (PoS) validation and staking, and third party Blockchain-as-a-Service (BaaS) operations. Because many payment stablecoins will run on the same decentralized infrastructure used by hundreds of millions of users globally, these activities create unique risks not easily captured by traditional regulatory disclosure.
Potential issues include hidden leverage through staking or mining positions, transaction ordering conflicts such as Maximum Extractable Value (MEV) attacks, affiliate self-dealing, and complex interdependencies across networks that could affect an issuer’s financial condition, liquidity, or redemption obligations even though their reserves may adequate. Auditchain’s proposal positions BNP as a core component of the application and licensing process under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), allowing regulators to evaluate “related activities” of applicants and affiliates in a holistic manner.
Central to the recommendation is a robust initial disclosure questionnaire containing 148 targeted questions organized into seven key categories:
This granular approach captures both initial application data and ongoing supervisory metrics, shifting from static, periodic snapshots to continuous, verifiable oversight.
To operationalize these disclosures, Auditchain proposes an XBRL-based taxonomy with 125 standardized elements, featuring type extensions to support multi-entity and multi-blockchain reporting that includes the issuer and its affiliates.
The proposed submissions would occur in structured, machine-readable format. This enables automated collection, validation, and analysis across all banking regulators.
The framework supports “equal-input/equal-output” verification, where algorithms can cross-reference reported figures against publicly available on-chain data to identify inconsistencies or attempts to obscure revenues from mining, validation, or staking. Event-driven disclosures would ensure timely reporting of material changes, such as shifts in staking allocations, new affiliate relationships, or alterations in network participation. By using open data standards, the system promotes interoperability with existing regulatory taxonomies and facilitates interagency coordination.
The BNP disclosure framework delivers significant advantages for regulatory oversight. First, it strengthens safety and soundness reviews by revealing how network participation impacts an issuer’s overall risk profile, liquidity position, and operational resilience — including exposure to blockchain-specific threats such as consensus failures or 51% attacks. Second, it dramatically improves detection of conflicts of interest through mandatory arm’s-length pricing analyses and clear transaction ordering policies, preventing scenarios where an affiliate’s mining or validation activities could prioritize its own interests over those of stablecoin holders, other credit unions and the generate public. Third, it enables scalable systemic risk monitoring, allowing pattern recognition across multiple filings to spot industry-wide concentrations or correlated exposures that could threaten broader financial stability. Overall, open standards reduce burdens on credit unions by providing standardized templates while equipping NCUA staff with AI-assisted tools for faster, more accurate reviews.
This proposed rulemaking represents the first phase of the NCUA’s implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). It focuses on the application, licensing, and approval process for credit unions and their subsidiaries to become permitted payment stablecoin issuers, along with limits on credit union investments in such issuers. A forthcoming second phase will propose regulations to implement the substantive standards and restrictions imposed by the GENIUS Act on these issuers, including reserve requirements, capital, liquidity, risk management, and operational protocols.
Auditchain Labs’ U.S. policy approach presents a forward-looking blueprint for modern regulatory oversight in the digital asset era. By embedding provable BNP disclosures into the stablecoin licensing process, the NCUA can harness blockchain’s inherent transparency tools to better safeguard credit union members, maintain financial stability, and accelerate responsible innovation. In an environment where public blockchains already underpin trillions in economic value, regulators cannot afford blind spots in shared infrastructure. Adopting these structured, verifiable requirements would position the United States as a global leader in technology-native, effective regulation of payment stablecoins.
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 transform the landscape of financial and crypto-asset disclosure.
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