In the three years since a small number of public companies started holding Bitcoin on their balance sheets, the digital-asset question has moved from fringe to structural. At least 154 public companies now hold Bitcoin worth more than $80 billion combined. Stablecoins have crossed $320 billion in market capitalisation and processed over $31 trillion in transactions in 2025 — a volume comparable to Visa and Mastercard's combined annual throughput. And for the first time, directors across every sector are being asked to approve treasury policies that would have been unthinkable at the boardroom table a decade ago.
This article is not an argument for or against digital assets. It is a handbook for the directors who will be asked to govern the decision - on Bitcoin, on stablecoins, and on the infrastructure that sits beneath both.
The Landscape, Part I: Bitcoin on the Balance Sheet
The corporate Bitcoin treasury movement has a clear shape in early 2026. Strategy (the company formerly known as MicroStrategy) holds more than 766,000 BTC - roughly 3.6% of the total supply that will ever exist. Japan's Metaplanet has become the world's third-largest public holder at just over 40,000 BTC, driven by a stated intention to reach 1% of total Bitcoin supply by 2027. Marathon Digital, Hut 8, and Riot anchor the crypto-mining cohort. Tesla remains in the mix with just over 11,500 BTC. And dozens of smaller companies - Genius Group (NYSE: GNS) among them - have adopted Bitcoin-first treasury reserve policies.
The top five holders account for most of the tonnage, but the long tail is where the most board-level debates are happening. Even after the volatility of early 2026, Q1 corporate accumulation hit record highs - over 62,000 BTC added by treasury buyers in a single quarter.
The Landscape, Part II: The Stablecoin Infrastructure Layer
If Bitcoin is the board-level digital-asset conversation about reserves, stablecoins are the board-level conversation about infrastructure. Dollar-pegged stablecoins - USDT, USDC, and a fast-growing field of bank-issued and fintech-issued alternatives - have moved from crypto-exchange liquidity layer to mainstream payments rail in less than 24 months.
The scale is worth sitting with. By April 2026, stablecoin market capitalisation had reached roughly $320 billion, with USDT and USDC accounting for over 80% of the circulating supply. In January 2026 alone, on-chain stablecoin movement exceeded $10 trillion. More than 1,600 US banks are now exploring stablecoin integration through providers like Jack Henry & Associates. Mastercard, Visa, Coinbase, and Stripe have all publicly committed to stablecoin rails. And the US GENIUS Act, signed into law on 18 July 2025, established a federal framework for Permitted Payment Stablecoin Issuers - the first coherent regulatory regime for dollar-pegged tokens anywhere in the world.
For boards, the stablecoin question is no longer 'should we hold some on the balance sheet?' It is broader and more strategic: is our company a user of stablecoin rails, an issuer of stablecoin instruments, or a participant in the infrastructure that underpins them? The answer has become a board-level question, not a treasury-management footnote.
Four Reasons the Question Is Reaching the Boardroom
Boards do not add digital assets to the treasury - or invest in stablecoin infrastructure - because it is fashionable. They are pushed there by a combination of macro conditions, accounting reform, legislative catalysts, and competitive dynamics that have compounded over the last 24 months.
The FASB accounting change is the most underappreciated of these. From 1 January 2025, ASU 2023-08 requires fair-value treatment of eligible crypto assets - gains and losses flow through net income each reporting period, and holdings appear separately on the balance sheet. That removed a structural disincentive to holding Bitcoin that had persisted under the prior impairment-only model. For many boards that had ruled out treasury Bitcoin specifically because of the accounting treatment, the FASB reform reopened the conversation overnight.
The GENIUS Act is the stablecoin equivalent. By codifying reserve requirements, disclosure rules, and permitted-issuer status, it de-risked stablecoins for US banks and corporates in a way no previous guidance had managed. Combined with the SEC's September 2025 custody guidance and the federal banking regulators' July 2025 crypto-safekeeping framework, the US now has - for the first time - a coherent if evolving regulatory map.
The Five-Pillar Governance Framework
When a management team brings any digital-asset proposal to the board - treasury allocation, stablecoin integration, infrastructure investment - my view is that the board should not vote on the proposal until five governance pillars are in place. Anything less is the board delegating its fiduciary oversight to the CFO's spreadsheet.
The framework is the same whether the underlying asset is Bitcoin, a USD-stablecoin, or equity in a regulated digital bank. Each pillar depends on the others. A board-approved treasury policy without a custody protocol is a hollow vote. A custody model without disclosure and risk-oversight creates securities-law exposure. And none of it works without a shareholder-communications approach that prepares investors for the volatility and scrutiny that come with the position.
Custody: The First Board Decision
Of the five pillars, custody is the one I spend the most time on at the board table. The reason is simple: custody failure is the only digital-asset risk that can take a company to zero overnight. Volatility can be weathered. A key loss, a custodian bankruptcy, or a smart-contract exploit generally cannot.
For public companies in 2026, the realistic choices are institutional custody and hybrid multi-sig. Pure self-custody at scale is extraordinarily difficult for a listed company to justify - the internal-controls, SOX, and auditor demands are severe. The SEC, FASB, and federal banking regulators issued guidance throughout 2025 on custody expectations, and companies developing digital-asset treasury strategies are now expected to disclose their custody arrangements explicitly.
The board's job on custody is not to pick the vendor. It is to test whether the management team has conducted a rigorous assessment - multiple finalists, insurance analysis, segregation review, and a documented contingency plan for custodian failure.
From the Boardroom: Genius Group's Digital-Asset Journey
At Genius Group, where I serve as Chief Legal Officer, Chief People Officer and Board Director, we have moved in deliberate steps across the full digital-asset stack: reserves, stablecoin infrastructure, and regulatory positioning. Each step has been a discrete board decision, documented, and sequenced with the governance framework above.
The first step was Bitcoin reserves. In November 2024 our Board adopted a Bitcoin-first treasury reserve policy, declaring Bitcoin the primary reserve asset of the company. In July 2025 the Board increased our Bitcoin treasury target tenfold - from 1,000 BTC to 10,000 BTC - with a 12-to-24-month horizon and a commitment to hold 90% or more of current and future reserves in Bitcoin. We paired that commitment with a $1.1 billion ATM facility with H.C. Wainwright & Co.
The second step was stablecoin infrastructure. On 15 April 2026, our Board approved an $8 million registered direct offering with American Ventures LLC as lead investor. American Ventures is a US investment vehicle that counts Eric Trump and Donald Trump Jr. among its investors.
$5.5 million of the $8 million proceeds went towards a Genius Group stakeholding of 9.9% equity in Jewel Financial Limited, the sole shareholder of Jewel Bancorp Limited. Jewel Bancorp is a Bermuda exempted company and the only dual-licensed digital bank in Bermuda - holding both a full banking licence and a Class F digital asset business licence issued by the Bermuda Monetary Authority under the Digital Asset Business Act 2018. Jewel is developing a US-dollar-denominated stablecoin, JUSD, alongside a suite of digital-asset banking services covering custody, settlement, and stablecoin infrastructure.
The strategic logic is layered. Holding 9.9% of a regulated dual-licensed digital bank positions Genius Group as a participant in, rather than a consumer of, stablecoin infrastructure. It accelerates the previously announced plan to become a Permitted Payment Stablecoin Issuer and Digital Asset Service Provider under the GENIUS Act.
A Bitcoin treasury is a reserve decision. A stablecoin infrastructure investment is a positioning decision. Boards that conflate the two - or delegate either - will find that the governance bill arrives later, usually with interest. — Eva Maria Mantziou, NED & CLO, Genius Group
A few practical observations from leading the legal and governance workstream on both tracks. First, the board pre-work matters more than the announcement. We restructured our board to include Blockchain and Web3 expertise before we formalised the Bitcoin strategy, not after. That sequencing is rarely discussed but it is the single most important step for credibility with institutional investors, auditors, and regulators.
Second, we integrated the digital-asset approach into our litigation and shareholder-distribution strategy. The 50/50 plan approved by our Board - under which proceeds from the ongoing RICO and securities class-action cases are divided equally between special dividends and Bitcoin treasury purchases -z¸¸¸[p;;;;;;;;;;;3 is only defensible as governance because it was deliberated at the board level with full transparency on volatility risk. The Jewel Bank investment sits alongside that commitment: same framework, same documentation discipline, same board-level transparency.
Third, investor-profile disclosure is not optional when high-profile backers are involved. When American Ventures was named as lead investor in the April 2026 offering, the Board's job was not to editorialise on the investor's political linkage — it was to make sure the disclosure was accurate, the related-party analysis was clean, and the shareholder-communications plan handled the inevitable questions. Boards that duck these conversations create reputational risk; boards that lead them create trust.
The Risks a Board Cannot Delegate
Every board has an instinct to delegate technical risk to management. On digital assets, five risk categories should stay at the board table - not as nominal oversight items, but as regular agenda topics.
Price and peg-break risk. Bitcoin can and does move 30–50% in weeks. Stablecoins can and do break their peg under stress. The board needs a stress-tested view of what each scenario does to covenants, earnings, and liquidity.
Custody and key-management risk. Loss of keys, custodian failure, or smart-contract exploit is unrecoverable. The board needs to review custody arrangements at least annually and after any vendor incident.
Regulatory and disclosure risk. The SEC, FASB, OCC, and home-country regulators are still shaping guidance. GENIUS Act implementation is ongoing. What is safe today may be insufficient tomorrow.
Accounting and tax risk. Fair-value accounting introduces earnings volatility; cross-border holdings add transfer-pricing and withholding complexity. The audit committee needs specialist support.
Reputational and related-party risk. A poorly communicated digital-asset strategy - or a high-profile investor whose connections are not explained clearly - invites activist pressure. The board needs a clear narrative and the courage to hold it through drawdowns.
Seven Questions Every NED Should Ask Before Voting Yes
- Is the allocation cap, the rebalancing policy, and the exit trigger written into a board-approved document - not just a management memo?
- Is the custody arrangement with a qualified institutional custodian, and has management documented the vendor-selection process?
- Has the audit committee reviewed how the company will report holdings under FASB ASU 2023-08, and does it have specialist support?
- Is there a board-level scenario analysis for a 50% drawdown or a stablecoin de-peg, and is there a liquidity plan that does not depend on selling at the bottom?
- Does the board committee with digital-asset oversight have members with demonstrable crypto, stablecoin, or regulatory expertise?
- Has the company articulated a shareholder-communications plan that explains the strategy - and any material investor relationships - in clear, volatility-neutral language?
- Is there a documented, board-approved plan for unwinding any part of the strategy if the thesis breaks, and a clear set of triggers for that conversation?
If the answer to any of these is 'no' or 'not yet,' the right move is to defer the vote. Digital-asset commitments are one-way doors: once a company is publicly committed, unwinding without damage is extraordinarily difficult. Better to delay a month than to undo a decade of governance credibility.
The Bigger Picture: The Board Table Has Changed
Bitcoin treasuries, stablecoin infrastructure, digital-asset banking, tokenised treasuries, on-chain payments - these are no longer specialist topics. They are board topics. The companies that position themselves credibly will be led by directors who can weigh fiduciary risk, technical custody, regulatory complexity, and strategic positioning in a single deliberation - and who can do it without either ideological fervour or ideological resistance.
That requires a different board. Not necessarily a different set of people - though expertise helps - but a different set of questions, a different disclosure discipline, and a different governance posture. The directors who adapt will be the ones companies compete to appoint over the next decade.
The directors who cannot will, quietly, be replaced.