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Stablecoins

Unstable

Payment measurement requires an attribution bridge from stablecoin transfers to economic purpose.

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A public ledger is exact about a narrow thing. It records that token balances changed under a particular protocol. It is usually silent about the invoice, payroll instruction, asset trade, collateral call, treasury policy, or internal routing decision that made the balances move.

The difficulty begins when an exact record is asked an economic question it does not contain. A transfer can be evidence in a payment analysis. It is not, without an evidentiary bridge, an observation of payment purpose.

Basis of analysis

Schär et al.'s BIS working paper carries the transaction-level record: 141,310,373 Ethereum transactions involving USDT, USDC, or PYUSD during calendar 2025, 241,423,906 stablecoin transfer events inside 593,096,940 event logs, and a 31.6% complex-transaction share holding 59.96% of those events, read from an archive node, public event signatures, and protocol factory contracts rather than proprietary end-user labels. Visa and Allium's published adjusted methodology, McKinsey and Artemis's approximately $390 billion annual rate, BCG and Allium's $350–550 billion range, and the raw denominators those studies report, up to $35 trillion, approximately $62 trillion, and an estimated $28 trillion from another provider in the BIS Annual Economic Report, supply the aggregate estimates. McKinsey's underlying labels and transaction set are proprietary, the Allium database and classifier were not released, and the address labels behind both payment estimates are unavailable. Corporate and legal filings carry the institutional claims: Visa's Form 10-K for the fiscal year ended 30 September 2025 and its December 2025 settlement announcement, Circle's Form 10-K for 2025 and its USDC terms, Public Law 119-27, and the OCC, FDIC, and Treasury proposals and the joint customer-identification proposal available on 15 July 2026. Filings of that kind state obligations, definitions, and reported totals rather than observed use. A separate doctrinal layer supplies the vocabulary: the CPMI glossary fixes the definitions that keep these objects apart. No source here identifies the purpose behind an individual transfer, supplies a global payment total, or connects any of those figures to S-1 framing, acquisitions, venture funding, or market pricing.

Record
A transfer event records a balance change; one blockchain transaction may emit many such events.
Adjustment
Mechanical and address-label filters can remove known noise, but adjusted transfer value still contains several economic functions.
Attribution
Payment purpose requires metadata, validated labels, counterparties, surveys, or a stated behavioural model.
Institution
Payment, settlement, redemption, reserve backing, issuer identity, and legal category answer different questions.
Inference
No valuation or adoption conclusion follows until the evidence crosses those boundaries explicitly.

Stablecoin movement and payment function are different units of observation. Recent work by the BIS, Visa and Allium, McKinsey and Artemis, and BCG and Allium approaches that interpretive problem through different datasets and methods (Bank for International Settlements 2026; Visa and Allium 2026; Higginson et al. 2026; Batra et al. 2026). This note supplies a compact discipline for reading those estimates.

One Token, Several Objects

The word volume often conceals the unit being counted. The minimum taxonomy is longer than the headline (Committee on Payments and Market Infrastructures 2016).

Object What the evidence can establish What it cannot establish by itself

Transfer event

A token contract recorded a change between addresses for an amount.

That two independent people transacted, or why value moved.

Blockchain transaction

An instruction executed, possibly through several contracts and transfer events.

That the instruction was a purchase rather than a swap, loan, liquidation, bridge operation, or internal action.

Adjusted transfer value

A stated filter removed selected anomalies, duplicate legs, labelled bots, or high-frequency activity.

Payment purpose. Visa’s adjusted categories still include exchange, lending, mint-and-burn, and decentralised-exchange activity (Visa and Allium 2026).

Payment

A payer discharged an underlying obligation to a payee for goods, services, payroll, remittance, or another stated purpose.

Finality on every leg, the identity of the beneficial parties, or direct redemption rights.

Settlement

An obligation was discharged under the governing contract or system rules.

A consumer purchase. Settlement may concern exchange trades, collateral, treasury balances, or obligations among payment-system participants.

Redemption

An eligible holder delivered a token to the designated redeemer for the referenced asset under stated terms.

That every secondary-market holder has identical access, timing, fees, or legal recourse.

Reserve

Specified assets support an issuer’s outstanding obligation at a stated date and under a stated reporting basis.

Payment use, continuous sufficiency under stress, or an unconditional claim by every holder on each reserve asset.

Issuer and legal category

A specified entity owes the obligation and a jurisdiction applies a statutory or contractual classification.

The token’s observed economic use. A product can be designed as a payment stablecoin while most recorded activity serves trading or settlement.

The asymmetry runs in one direction. A known payment can produce one or more ledger records; ledger records do not uniquely recover the payment that produced them. Inference can move from verified purpose to transfer, and it cannot move back without additional evidence.


What the 2025 Record Supports

The strongest public evidence establishes a unit-of-observation problem, not a global payment total.

Schär et al. (2026) analysed 141,310,373 Ethereum transactions involving USDT, USDC, or PYUSD during calendar 2025. Those transactions emitted 241,423,906 stablecoin transfer events inside a dataset of 593,096,940 event logs. The authors classify 31.6% of the transactions as complex; because complex transactions emit several events, 59.96% of transfer events occurred inside that class. Their inputs came from an archive node, public event signatures, and protocol factory contracts rather than proprietary end-user labels.

That is unusually strong evidence that event counts and transaction counts are different objects. The same record fixes the boundary of the finding: the study covers three tokens on Ethereum, not every token and chain. Transaction complexity identifies structure; it does not observe an invoice or prove that every simple transfer purchased a good or service.

Visa’s public dashboard addresses another layer. Its adjusted methodology counts only the largest stablecoin movement inside a transaction, uses more than three million probabilistic address labels, and applies thresholds of 1,000 transactions or $10 million over 30 days to certain unlabelled addresses. The filters are explicit and useful. Yet the retained categories include centralised-exchange deposits and withdrawals, decentralised-exchange activity, lending, investment funds, ramps, and minting and burning. Adjusted therefore means adjusted under that model, and it does not mean payments (Visa and Allium 2026).

The published payment studies proceed by adding purpose assumptions:

  • McKinsey and Artemis estimated approximately $390 billion at an annual rate based on December 2025 activity. Their method tags known payment and custody infrastructure, assumes 20% of selected custody and treasury-provider volume is B2B payment activity, derives peer-to-peer estimates from exchange advertisements, and assumes 10% of selected stablecoin-to-fiat trading volume represents remittances. The underlying labels and transaction set are proprietary (Higginson et al. 2026).

  • BCG and Allium estimated $350–550 billion of observable bilateral goods-and-services payments during calendar 2025. They begin with approximately $62 trillion of gross transfers, retain $4.2 trillion after mechanical exclusions, then classify behaviour by direction, frequency, size, counterparties, and timing. They exclude approximately $950 billion of unclear activity from the payment range. The Allium database and classifier were not released (Batra et al. 2026).

The proximity of the two payment estimates is suggestive. It is not independent replication. The time bases differ, the address labels are unavailable, the models make different boundary choices, and neither publication supplies a ground-truth validation set, confusion matrix, or executable pipeline.

The raw denominator is unstable for the same reason. McKinsey reports public estimates of up to $35 trillion for 2025; BCG and Allium report approximately $62 trillion; the BIS Annual Economic Report reports an estimated $28 trillion using another provider. Token coverage, chain coverage, anomaly handling, internal-event treatment, price conversion, and the distinction between transfer events and transactions differ. These figures cannot be treated as three measurements of one fully specified quantity (Higginson et al. 2026; Batra et al. 2026; Bank for International Settlements 2026).


Visa Is Not the Denominator

Visa reported $14.2 trillion of payment volume for the fiscal year ended 30 September 2025. Its filing describes payment volume as activity on Visa products for purchased goods and services; nominal volume is provided by its financial-institution clients and is subject to Visa’s review. Cash activity sits in a separate total-volume measure (Visa Inc. 2025a).

That statistic is not commensurable with a calendar-year stablecoin transfer aggregate. It has a defined commercial function, a different reporting period, a network and client population, and institutional metadata that a public token log does not contain. Placing the figures beside each other can illustrate the magnitude of unlike systems, and it cannot establish relative payment adoption.

Visa’s own stablecoin programme shows why the layers must remain separate. In December 2025, Visa said its monthly USDC settlement activity had exceeded a $3.5 billion annualised run rate. Participating issuers and acquirers use USDC to discharge obligations to Visa. Visa stated that the consumer card experience does not change. A cardholder can therefore make an ordinary card payment while USDC appears later as an institutional settlement asset, and counting the settlement leg as a second consumer payment would confuse two valid records of different obligations (Visa Inc. 2025b).

Three quantities that cannot substitute for one another
Quantity
Institutional object
Required evidence
Visa payment volume
Purchases for goods and services
Network and client records
Visa USDC settlement
Issuer and acquirer obligations to Visa
Settlement programme records
Stablecoin transfer value
Token balance movements across covered ledgers
Chain data plus an explicit attribution model

Reserve, Redemption, and Issuer Are Separate Again

USDC makes a useful case: Circle’s audited filing reveals both the issuer economics and the limits of analogy. Circle reported that reserve income was 96.0% of total revenue in 2025. At 31 December 2025 it reported $75.266 billion of USDC in circulation and approximately 88% of USDC reserves in the Circle Reserve Fund, a government money-market fund managed by BlackRock; the remainder was principally cash (Circle Internet Group 2026).

Those facts support a precise statement: Circle’s 2025 revenue was overwhelmingly sensitive to reserve balances and yields. They do not turn Circle into a money-market fund administrator, and they do not establish an equity valuation. A USDC holder holds a token subject to contractual and jurisdiction-dependent redemption rights. Ownership of a share in the Circle Reserve Fund does not follow, and Circle maintains the reserve arrangement and assumes the issuer’s redemption obligation.

Access to that obligation also depends on status. Circle’s USDC terms outside the European Economic Area distinguish Circle Mint customers from other holders. A non-customer generally cannot redeem directly with Circle unless eligible for and accepted into Circle Mint; EEA holders are governed by a separate white paper and legal regime. The terms also reserve compliance, blocking, and delay powers and state that USDC is not deposit-insured. "Fully backed," "directly redeemable," and "cash equivalent" are therefore not synonyms (Circle Internet Financial 2025).

The legal label adds another boundary. The GENIUS Act became Public Law 119-27 on 18 July 2025. It defines a payment stablecoin partly by design and an issuer’s fixed-value redemption obligation, while excluding national currency, deposits, and securities. That statutory definition does not classify each observed transfer by user purpose (U.S. Congress 2025).

The Act’s operative framework was not yet in force on 15 July 2026. Section 20 sets effectiveness at the earlier of 18 months after enactment or 120 days after primary federal regulators issue final implementing regulations. The official materials available on that date were proposed rules: the OCC’s principal proposal, the FDIC’s prudential proposal, Treasury’s AML and sanctions proposal, and a joint customer-identification proposal. The Act’s one-to-one reserve, disclosure, and redemption requirements were therefore not yet the operative federal basis for every U.S. stablecoin claim (Office of the Comptroller of the Currency 2026; Federal Deposit Insurance Corporation 2026; U.S. Department of the Treasury 2026; Federal Reserve Board 2026).

A reserve disclosure cannot establish payment purpose, and a payment classifier cannot establish reserve quality. A statutory product definition cannot do either job retroactively.


Market Inference

The available record does not identify a causal chain from aggregate-volume analogies to S-1 framing, acquisitions, venture funding, or market pricing.

Circle’s filing reports both high on-chain activity and a reserve-income-dominated business model. Visa reports both card payment volume and stablecoin settlement. These disclosures show that institutions track several layers at once. They do not reveal which metric investors relied on, what counterfactual valuation would have prevailed, or whether a funding decision changed because of a Visa comparison.

Goodhart’s law would require evidence that protocol operators targeted a stablecoin-volume statistic. Multiple event logs and routing legs arise from system design whether or not anyone optimises a headline. The demonstrated problem is construct validity: the measure does not uniquely represent the economic concept assigned to it.

The market inference stops there. Anyone using raw or mechanically adjusted transfer value as a proxy for payment adoption assumes a bridge that the ledger does not supply. Whether that assumption affected a price is a separate empirical question.


Measurement Protocol

Four rules are enough to prevent the category collapse.

  1. Name the unit. State whether a figure counts event logs, blockchain transactions, token value, adjusted token value, payment instructions, settled obligations, or redemptions.

  2. Freeze the universe. Publish dates, chains, contracts, native and bridged-token treatment, price source, anomaly rules, and versioned address labels.

  3. Expose the purpose bridge. For behavioural classification, publish features, thresholds, ambiguous-class treatment, validation sampling, class-level precision and recall, and sensitivity to alternative boundaries.

  4. Match the institution. Compare payment with payment, settlement with settlement, and issuer economics with issuer economics. Do not let a legal product name stand in for observed use.

Stronger claims require a reproducible classification pipeline and an independently labelled validation sample, or records such as invoices and platform data that connect transfers to underlying obligations. A larger transfer total or agreement between proprietary models cannot supply that connection on its own.


Scope of Inference

This analysis concerns selected fiat-referenced tokens and the institutional claims surrounding USDC. Its reserve, redemption, and legal conclusions do not extend to crypto-collateralised, commodity-referenced, algorithmic, yield-bearing, or tokenised-deposit arrangements. The BIS transaction study is Ethereum-specific, the commercial payment estimates depend on unpublished data, and regulatory status is stated as of 15 July 2026.

The sources fix both population and period. Transaction-level evidence covers USDT, USDC, and PYUSD on Ethereum during calendar 2025. The payment estimates cover December 2025 activity at an annual rate in one case and calendar 2025 in the other. The three raw denominators come from different compilations: public estimates reported by McKinsey, Allium’s figure via BCG, and another provider via the BIS Annual Economic Report, each applying different coverage and handling rules. Visa’s payment volume covers the fiscal year ended 30 September 2025, and its USDC settlement figure is an annualised run rate for monthly settlement activity, stated in December 2025. Circle’s circulation and reserve figures are dated 31 December 2025, and federal regulatory status is stated as of 15 July 2026.

Each result sits on one layer and does not travel to another. A ledger record reports that balances changed; an adjustment model reports what a stated filter removed. Purpose attribution requires metadata, validated labels, counterparties, surveys, or a stated behavioural model, which a public token log does not supply by itself. Corporate filings and terms report obligations an issuer or a network has assumed, while a statute reports a legal category. No finding here may be carried from one of those layers to another without evidence that crosses the boundary explicitly.

Several questions fall outside the boundary: payment purpose for any individual transfer, a global payment total, relative payment adoption between card and stablecoin rails, continuous reserve sufficiency under stress, an unconditional claim by every holder on each reserve asset, an equity valuation for Circle, and any causal chain from aggregate-volume analogies to S-1 framing, acquisitions, venture funding, or market pricing. Whether protocol operators targeted a stablecoin-volume statistic falls outside what this record identifies, and whether a proxy assumption affected a price is a separate empirical question.


Falsification

The affirmative claim is narrow: a recorded stablecoin transfer establishes that a token balance changed under a protocol, and it establishes payment purpose, settlement, redemption, reserve quality, or legal category only where separate evidence connects those layers. Two of the five observations below would defeat that claim; three would defeat findings it rests on, and those three name the sections they would unseat.

  1. Transfer logs for USDT, USDC, or PYUSD carrying the invoice, payroll instruction, asset trade, collateral call, treasury policy, or internal routing decision behind a balance change would defeat the affirmative claim at its source, since the argument rests on a public log being usually silent about each of them. A reader can test the condition against the same Ethereum event data the working paper reads.

  2. A payment classifier published with its features, thresholds, ambiguous-class treatment, validation sampling, class-level precision and recall, and sensitivity to alternative boundaries, and released as an executable pipeline that recovers payment purpose from public transfer records alone at validated class-level accuracy against an independently labelled validation sample, would supply the purpose bridge the ledger does not itself provide and would defeat the affirmative claim’s requirement that separate evidence connect those layers. The record read here does not contain that release: neither payment publication supplies a ground-truth validation set, confusion matrix, or executable pipeline, and the Allium database and classifier were not released.

  3. A recomputation over calendar 2025 Ethereum data for the same three tokens returning transfer-event and transaction counts that coincide, so that a 31.6% complex-transaction share does not carry 59.96% of transfer events, would defeat the finding in What the 2025 Record Supports that event counts and transaction counts are different objects, and would remove the evidential basis of the taxonomy in One Token, Several Objects. Schär et al. drew their inputs from an archive node, public event signatures, and protocol factory contracts, so this condition resolves against public data.

  4. A stablecoin aggregate compiled on Visa’s own payment-volume definition, purchases of goods and services over the fiscal year ended 30 September 2025, would defeat the claim in Visa Is Not the Denominator that the $14.2 trillion figure and a calendar-year transfer aggregate are not commensurable. Such an aggregate would have to carry nominal volume reported by financial-institution clients and subject to a network operator’s review, together with the institutional metadata that a public token log does not contain, and the claim under test is that public ledger data does not supply those inputs. Visa’s filing publishes the definition against which any candidate aggregate is measured.

  5. USDC terms granting every secondary-market holder direct redemption with Circle, without regard to Circle Mint eligibility or the separate EEA regime, would defeat the status-dependence reported in Reserve, Redemption, and Issuer Are Separate Again and would extend "directly redeemable" to every holder. The compliance, blocking, and delay powers the terms reserve, together with their statement that USDC is not deposit-insured, would keep that term distinct from "fully backed" and "cash equivalent." Circle’s published terms are the document to read.

Three of the five resolve against material a reader can obtain today: Ethereum event logs behind the first and third conditions, and Circle’s published terms behind the fifth. The other two wait on a released classifier and on an aggregate built to Visa’s definition, neither of which appears in the sources read here, and that absence is part of what this note reports rather than a defect in the test. None of the five asks for a forecast, which keeps refutation conditions apart from the measurement programme set out above.


Stablecoins can be useful for payment, trading, collateral, treasury, and settlement. Precision does not require choosing one function as the real one. It requires refusing to let movement impersonate purpose.

The ledger tells us that value moved. Scholarship begins where that sentence ends.

References

Batra, Inderpreet, et al. 2026. "Stablecoin Payments: The Truth Behind the Numbers." Boston Consulting Group and Allium, January 2026. BCG.

Bank for International Settlements. 2026. "Anchoring Trust in Money: Innovation Beyond Stablecoins." Annual Economic Report 2026, chapter 3. BIS.

Circle Internet Group, Inc. 2026. "Annual Report for the Year Ended December 31, 2025." Form 10-K. SEC.

Circle Internet Financial, LLC. 2025. "USDC Terms." Updated December 12, 2025. Circle.

Committee on Payments and Market Infrastructures. 2016. "Glossary." BIS.

Federal Deposit Insurance Corporation. 2026. "FDIC Approves Proposal to Implement GENIUS Act Requirements and Standards." April 7, 2026. FDIC.

Federal Reserve Board. 2026. "Federal Reserve Board Requests Comment on Proposal to Require Certain Payment Stablecoin Issuers to Maintain an Effective Customer Identification Program." June 18, 2026. Federal Reserve.

Higginson, Matt, et al. 2026. "Stablecoins in Payments: What the Raw Transaction Numbers Miss." McKinsey & Company and Artemis Analytics, February 18, 2026. McKinsey.

Office of the Comptroller of the Currency. 2026. "GENIUS Act Regulations: Notice of Proposed Rulemaking." Bulletin 2026-3, February 25, 2026. OCC.

Schär, Fabian, Anneke Kosse, Tara Rice, Takeshi Shirakami, and Jirapat Siridhasanakul. 2026. "The Anatomy of Stablecoin Transactions." BIS Working Papers 1359. BIS.

U.S. Congress. 2025. Guiding and Establishing National Innovation for U.S. Stablecoins Act. Public Law 119-27, July 18, 2025. GovInfo.

U.S. Department of the Treasury. 2026. "Treasury Proposes Rule to Implement the GENIUS Act’s Requirements to Counter Illicit Finance." April 8, 2026. FinCEN.

Visa Inc. 2025a. "Annual Report for the Year Ended September 30, 2025." Form 10-K. SEC.

Visa Inc. 2025b. "Visa Launches Stablecoin Settlement in the United States." December 16, 2025. Visa.

Visa and Allium. 2026. "Transactions: Adjusted Transaction Methodology." Visa Onchain Analytics.