Reserve evidence and attestation: stages and deadlines

Reserve evidence and attestation is the process that turns an internal claim — "the assets we hold match the tokens in circulation" — into a checked, dated statement an outside professional is willing to sign. It runs in a fixed sequence: reconciliation, engagement, fieldwork, draft report, final report, submission, publication. Skipping a stage does not save time. It moves the delay to a later point, where it is harder to fix.

What changes once the cycle starts

Once an issuer commits to a token backed by reserve assets, the reconciliation between assets held and tokens outstanding becomes a recurring obligation rather than a one-off exercise. Each cycle produces its own reconciliation, its own review by the attestor, and its own report. A gap in one cycle does not disappear on its own. It carries into the next reconciliation as an unexplained variance, and unexplained variances attract closer review.

The practical consequence is timing discipline. An attestation report that arrives late, or that covers a period with a gap, reads differently to a supervisor than one filed on schedule. The content may be identical; the pattern around it is not, and pattern is what draws follow-up questions.

Why attestation is not the same as an audit

An attestation is narrower than a full financial audit. It answers one question — does the stated reserve match the stated token supply at a given date — rather than forming an opinion on the issuer's financial statements as a whole. That narrower scope is why attestation cycles run more often than annual audits, and why the same attestor can often complete a repeat cycle in under three weeks once the engagement is established.

Stages, in the order they actually happen

The first cycle runs long because the engagement step exists only once. Later cycles compress toward fieldwork and reporting, since the scope and data room are already set up.

What to do, in order

1. Assign one internal owner for the reserve register before the first cycle starts. A shared owner slows every later step.
2. Select an attestor with experience in reserve or custody engagements, not general audit experience alone.
3. Agree the scope letter before asset composition changes. A scope written against one custodial structure does not automatically cover a different one.
4. Prepare custodial statements and bank confirmations for the same cut-off date as the reconciliation, not a nearby date.
5. Resolve any variance found during fieldwork before the draft report is issued, not after.
6. Route the final report to the supervisor and, separately, to the publication channel used for token holders.

Common reasons a cycle runs long

• The reconciliation date used internally does not match the cut-off date on the custodian's statement.
• A wallet address included in the token supply ledger is missing from the reserve register, or the reverse.
• A custodian changes its statement format between cycles, and the attestor has to re-map the data before testing it.
• A non-cash reserve asset needs a valuation source that was not agreed in the original scope letter.

Who decides and how

The attestor decides whether the evidence supports the requested opinion — reasonable or limited assurance — and states that decision in the report itself, not informally beforehand. The issuer's own governing body approves the report before submission. That approval is not a formality: the board is accepting responsibility for what the report says. The supervisor then reviews the submitted report against the issuer's disclosed policy and either accepts it or asks for clarification. Clarification requests are the most common outcome for a first submission.

Forks depending on your situation

If reserve assets sit with a single custodian in one jurisdiction, the reconciliation stage is short and fieldwork can start almost immediately after the scope letter is signed.

If reserve assets are split across several custodians, or across jurisdictions, the reconciliation stage takes longer, and the attestor typically asks for a consolidated statement before starting fieldwork on the underlying accounts.

If reserve assets include instruments that are not cash — short-dated government paper, for example — the attestor will ask for valuation evidence alongside the custodial statement, adding a step that pure cash reserves do not need.

If a discrepancy surfaces during fieldwork, the sequence pauses at that stage. The draft report is not issued until the discrepancy is explained or corrected, and the correction is dated to the period in which it occurred, not to the period in which it was found.

The point of no return

Once the final report is signed and submitted, a quiet correction is no longer available. Any material issue found afterwards has to be disclosed as a restatement, addressed in the following cycle's report, and explained to the supervisor as part of that cycle. This is why internal review before signing matters more than speed. A fast but wrong report costs more time overall than one issued a few days later.

What comes next in the process

Once the reserve evidence and attestation cycle is complete, most issuers move directly to notifying the supervisor of the outcome. That step has its own timing and its own document set: Notification to the supervisor step by step.

Sources and the limit of this page

This page describes a repeated operational sequence, not a legal test for any particular reserve structure. Where the reserve counterparty sits outside the issuer's home market, the underlying counterparty record may need its own check: Counterparty in Norway.

Where a custodial or attestation document originates in a jurisdiction the issuer does not operate in day to day, the document itself may need separate verification before it can support a reconciliation: Document in Malta.

Where the reserve structure touches a jurisdiction with its own disclosure regime, a jurisdiction-level check clarifies what can and cannot be confirmed from public sources: Jurisdiction in United States.

If part of the data supporting your attestation flows through a delivery partner rather than your own systems, our treatment of that arrangement is set out separately: Subprocessors, including local delivery partners in practice.

Verified

This page was reviewed against current supervisory practice and standard attestation methodology as applied to reserve-backed tokens. It does not cite a specific statutory provision, because the sequence described here is procedural: it holds regardless of which national supervisor receives the report. Where a specific statutory deadline applies to your issuance, confirm it with the supervisor directly rather than assuming it from this page.

If your licence is already under review

An attestation gap found during an active supervisory review changes the sequence above. The reconciliation may need to be produced faster, and the supervisor's request takes priority over the routine cycle. If that is your situation: When a licence is suspended pending review explained.

FAQ

How long does reserve evidence and attestation take in practice?

A first cycle usually takes four to seven weeks from engagement to submission. A repeat cycle, once the data room and scope are already set, compresses to two to three weeks in most cases.

Which documents are needed to start?

The reserve asset register, the token supply ledger for the same cut-off date, custodial and bank statements, and the prior attestation report if this is not the first cycle. The scope letter should reference all four before fieldwork begins.

What happens if the other side does not respond?

If a custodian or bank does not confirm a balance within the fieldwork window, the attestor cannot complete the opinion for that period. Escalate the request in writing, and if the delay continues, disclose the outstanding confirmation rather than wait past the reporting deadline.

— Aleks Vaher, AURELIS