First define what "completion of payment" means
When the parties agree to and lawfully use stablecoin settlement, on-chain delivery may form part of performance; however, whether a contractual debt has been discharged still depends on the applicable law and the agreement, and a general conclusion cannot be drawn from a single transaction hash alone. If the contract requires the payee's bank account to receive a specified fiat currency, sending stablecoins to an intermediary institution is merely one step in the overall process.
Research by the BIS Committee on Payments and Market Infrastructures (CPMI) on stablecoin cross-border payments incorporates on- and off-ramp arrangements into its overall analysis. For payment products, this means that on-chain speed and the speed at which funds ultimately become available should be stated separately; round-the-clock on-chain operation cannot replace the processing capacity of the stablecoin seller, banks and local payment channels.
Purely on-chain services may also be regulated services
Article 82 of the EU's MiCA sets out requirements such as client agreements for crypto-asset transfer services on behalf of clients. ESMA's public Q&A further clarifies that activities meeting the definition of a transfer service, even if embedded in other crypto-asset services, should be analyzed against the corresponding authorization requirements. Therefore, "we only transfer coins, not fiat currency" cannot automatically exclude regulation.
A distinction should be drawn between an enterprise paying its own debts with assets it controls and a platform accepting instructions from others to transfer assets on their behalf. This is not to say that the former is risk-free in all jurisdictions, but that the roles of the parties differ, and the same set of licensing conclusions cannot be applied interchangeably merely because an on-chain address appears in both cases.
Information that does not go on-chain still requires someone to be responsible for it
Suppose a procurement contract is denominated in US dollars and the supplier agrees to receive a certain stablecoin. The parties must still specify the conversion time point, the network used, how shortfalls or mistaken transfers are handled, and whether a top-up is required if the asset depegs. If all of these are left blank, disputes after receipt will merely shift from the banking stage to the contract level; they will not disappear.
Tax records cannot be omitted either. The Singapore IRAS guidance on enterprises accepting or using digital tokens for payment requires treatment under the applicable income tax rules and generally requires transactions to be recorded at their Singapore dollar value. This is merely a jurisdictional example of tax treatment; it does not mean that any token payment is licensed for business, nor that every country adopts the same valuation method.
Design systems backwards from the delivery outcome
It is advisable to link client authorization, payee information, invoices, on-chain records, conversion and fiat disbursement evidence into a complete chain of evidence. Products that only provide on-chain delivery should clearly define their endpoint and limitations; products that promise fiat currency arrival should implement local disbursement and contingency plans for failures. Do not, in pursuit of a "fully on-chain" concept, exclude from the product the evidence, refunds or customer service responsibilities that clients actually need.
Recommended actions
- Determine whether the contract provides for token delivery or the receipt of fiat currency in a bank account.
- Review payments made from one's own assets and transfers made on behalf of clients separately.
- Specify the currency, network, valuation time, receipt standard and supplementary payment for anomalies.
- Establish linked reference numbers for contracts, orders, on-chain transactions and payment vouchers.
Information note: This article provides general information and does not replace legal advice based on specific facts.
References
- Considerations for the use of stablecoin arrangements in cross-border payments — BIS／CPMI
- Article 82 of MiCA: transfer services on behalf of clients — EU regulations / ESMA official rulebook
- ESMA Q&A 2071 — ESMA / European Commission responses
- Taxable & Non-Taxable Income：Tax Treatment of Digital Tokens — Inland Revenue Authority of Singapore (IRAS)
