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TL;DR
The July 18, 2026 Rulemaking Deadline
The GENIUS Act, Public Law 119-27, was signed on July 18, 2025. Section 13 required the primary federal payment stablecoin regulators to promulgate implementing regulations within one year of enactment, setting a deadline of July 18, 2026 [1].
As of that date, ten notices of proposed rulemaking had been issued across the federal agencies. None had been finalised [1][2]. Several comment periods remained open past the deadline [1].
A notice of proposed rulemaking is a draft rule issued for public comment. It is not binding, and its provisions may change before a final rule is adopted.
The Ten Proposed Rules
Rulemaking responsibility under the GENIUS Act is distributed across Treasury and the federal banking agencies, with FinCEN and OFAC covering anti-money laundering and sanctions requirements.
The OCC proposal. Issued February 25, 2026, the OCC's notice of proposed rulemaking addresses the regulations the OCC is required to promulgate under the GENIUS Act other than those relating to the Bank Secrecy Act, anti-money laundering and sanctions [4]. The majority of the proposed rules would sit in a new 12 CFR Part 15, covering standards for reserves, redemption, capital, liquidity, risk management and reporting. The proposal also revises capital adequacy standards in 12 CFR 3, prompt corrective action regulations in 12 CFR 6, assessment of fees in 12 CFR 8, and rules of practice and procedure in 12 CFR 19 [4]. The Conference of State Bank Supervisors noted that the proposal asked over 200 questions [3]. The OCC issued a separate proposal covering Bank Secrecy Act and sanctions compliance standards on June 22, 2026 [5].
The Treasury state regime proposal. Announced April 1, 2026 and published in the Federal Register on April 3, this was Treasury's first proposed regulation under the GENIUS Act, with comments due June 2, 2026 [6][7]. Under the Act, payment stablecoin issuers with consolidated total outstanding issuance of not more than ten billion dollars may opt for regulation under a state-level regime, provided that regime is substantially similar to the federal framework [6]. The proposal sets out the principles Treasury would apply in making that determination.
The proposal uses the OCC's proposed implementation rule as a reference point for prudential expectations. On reserves, Treasury proposes that states may permit reserve assets beyond those listed in Section 4(a)(1)(A) only where the OCC has approved those assets as similarly liquid federal government-issued assets under Section 4(a)(1)(A)(vii). Under the proposal, states may be more conservative than the OCC but not more permissive [8]. Treasury also proposes that the definition of the federal regulatory framework include relevant implementing rules and interpretations rather than the statutory text alone [8].
Earlier Treasury activity. Treasury issued an advance notice of proposed rulemaking on September 19, 2025, seeking comment on temporary safe harbours, clarification of statutory terms, methods for detecting illicit activity, evaluation of whether foreign stablecoin regimes are comparable to the GENIUS Act regime, and tax and insurance implications [9][10]. In March 2026, Treasury issued a report to Congress covering its findings on technologies to counter illicit finance involving digital assets [9].
The Effective Date
Section 16 provides that the Act takes effect on the earlier of two dates: 18 months after enactment, which is January 18, 2027, or 120 days after the date on which the primary federal payment stablecoin regulators issue any final regulations implementing the Act [11].
Because final regulations were not issued by the one-year mark, the first of those two dates applies. The Act takes effect on January 18, 2027 [1][2].
The January 18, 2027 date is fixed by reference to the enactment date and does not shift if rulemaking continues past that point. The period between the issuance of final rules and the effective date is the interval available to issuers for implementation of reserve, custody, reporting and registration requirements [1].
Section 16 also requires the primary federal payment stablecoin regulators to notify Congress upon beginning to process applications under the Act [11].
Statutory Requirements and Open Questions
Certain requirements are set by the statute itself and are not dependent on the outcome of rulemaking.
Issuers must hold reserves backing outstanding tokens on a one-to-one basis in cash, short-dated Treasuries and similar instruments, and must publish monthly disclosures of reserve composition. Issuers are prohibited from paying yield or interest to holders. Banks and credit unions may issue only through subsidiaries. Issuers with consolidated outstanding issuance of not more than ten billion dollars may elect state supervision where the state regime qualifies [6][12].
Matters that remain subject to pending rulemaking include which additional assets qualify under Section 4(a)(1)(A)(vii), the process by which state regimes will be certified as substantially similar, the application and approval process across each supervising agency, and the final form of anti-money laundering and sanctions programme requirements [3][9].
On July 13, 2026, the American Bankers Association and state banking groups submitted a request for clearer language on the Act's yield provisions and asked that rules prevent payment stablecoins from acting as deposit substitutes [2]. In January 2026, Bank of America chief executive Brian Moynihan stated that up to six trillion dollars in deposits, approximately one third of US commercial bank deposits, could shift to stablecoins if regulators were to permit yield payments on them [13].
During the 2026 legislative session, several states adopted legislation empowering their state banking or securities regulators to license and supervise stablecoin issuers in compliance with the GENIUS Act [3].
Cross-Border Provisions: Sections 8 and 15
Two provisions of the Act address stablecoins issued outside the United States.
Section 15 addresses reciprocity. It directs the Federal Reserve, in collaboration with the Secretary of the Treasury, to create and implement reciprocal arrangements or other bilateral agreements between the United States and jurisdictions with substantially similar payment stablecoin regulatory regimes, for the purpose of facilitating international transactions and interoperability with United States dollar-denominated stablecoins issued overseas [11].
Treasury's September 2025 advance notice sought comment on how it should evaluate whether foreign regimes are comparable to the GENIUS Act regime [9][10]. In a comment letter submitted in November 2025, Circle recommended that recognition of foreign regimes require effective ongoing supervision rather than registration-only or light-touch models, and that criteria and determinations be published [14].
Section 8 addresses foreign issuer compliance. Under the Act, foreign issuers of payment stablecoins must comply with lawful orders. Where an issuer fails to do so, Treasury may designate the issuer as noncompliant, which results in a prohibition on digital asset service providers facilitating secondary market trading of that issuer's payment stablecoin. Treasury may issue licences and waivers, and is directed to specify the criteria a noncompliant foreign issuer must meet for Treasury to determine that it is no longer noncompliant [10].
Foreign issuer registration is one of the four proposals Treasury issued during the first year [2].
For a comparison of how the US framework sits alongside those in the EU, Canada, Hong Kong and Singapore, see our global payment licensing landscape guide.
Market Data Over the Period
The Federal Reserve reported aggregate stablecoin market capitalisation of 317 billion dollars as of April 6, 2026, representing more than 50% growth since early 2025. The same analysis noted that market capitalisation flattened during the final quarter of 2025 and the first quarter of 2026 [15]. At the one-year anniversary the market was reported at approximately 310 billion dollars, comprising roughly 184 billion dollars in USDT and 73 billion dollars in USDC [2].
Approximately 99% of stablecoin supply is denominated in US dollars [16].
On reserve composition, the Federal Reserve reported that according to attested disclosures, USDT maintains approximately 1.04 times reserves for each token in circulation, with approximately 0.74 times in assets qualifying as higher quality, defined as Treasuries, repurchase agreements backed by Treasuries, and bank deposits. USDC maintains full one-times backing in higher-quality reserves [15]. The same analysis reported that stablecoin transaction volumes on Ethereum rose by 50% following the GENIUS Act's enactment [15].
Aggregate stablecoin transfer volume for 2025 has been reported in the range of 28 to 62 trillion dollars depending on measurement methodology, of which an estimated 350 to 550 billion dollars represented real-economy payment activity, with the remainder representing trading and transfers between wallets and exchanges [16].
On institutional activity, JPMorgan has operated deposit tokens through its Kinexys platform since June 2025 and expanded to live payments for institutional clients in early 2026. That product is classified as a deposit token rather than a payment stablecoin under the GENIUS Act [13]. Bank of America, Citigroup and Wells Fargo explored a joint stablecoin project in 2025, and Wells Fargo separately piloted a digital cash token for internal settlement [13]. Tether launched USAT in January 2026 through Anchorage Digital [17].
On business adoption, an EY survey of 350 companies found that more than 50% of non-users planned to adopt stablecoins within six to twelve months, with cross-border payments cited as the primary intended use case [18]. Survey data reported by Reap identified lower transaction costs and faster cross-border payments as the leading stated reasons for adoption, and paying suppliers cross-border and accepting cross-border payments as the leading use cases [16].
Timeline
- July 18, 2025. GENIUS Act signed into law as Public Law 119-27 [1].
- September 19, 2025. Treasury issues advance notice of proposed rulemaking [10].
- February 25, 2026. OCC issues its principal notice of proposed rulemaking [4].
- March 2026. Treasury issues report to Congress on technologies to counter illicit finance [9].
- April 1, 2026. Treasury announces its state regime similarity proposal, published in the Federal Register April 3 [6][7].
- April 10, 2026. FinCEN and OFAC issue proposed anti-money laundering and sanctions compliance requirements for permitted issuers [19].
- June 2, 2026. Comment deadline on Treasury's state regime proposal [7].
- June 22, 2026. OCC issues proposed Bank Secrecy Act and sanctions compliance standards [5].
- July 13, 2026. American Bankers Association and state banking groups submit request regarding yield provisions [2].
- July 18, 2026. Statutory rulemaking deadline under Section 13. Ten proposals issued, none finalised [1][2].
- January 18, 2027. Statutory effective date under Section 16 [11].
For background on how stablecoin settlement operates, see our complete guide to stablecoin payments, and for the provisions of the Act as enacted, our earlier analysis of the GENIUS Act and cross-border payments.
Sources
[1] crypto.news. "The GENIUS Act turned one by missing its own deadline." July 2026. https://crypto.news/the-genius-act-turned-one-by-missing-its-own-deadline/
[2] GN Crypto. "U.S. Regulators Miss GENIUS Act Deadline for Stablecoin Rules." July 2026. https://www.gncrypto.news/news/us-regulators-miss-genius-act-deadline-stablecoin-rules/
[3] Conference of State Bank Supervisors. "A Look Back at One Year of GENIUS Implementation." July 2026. https://www.csbs.org/look-back-one-year-genius-implementation
[4] Office of the Comptroller of the Currency. "GENIUS Act Regulations: Notice of Proposed Rulemaking." Bulletin 2026-3. https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-3.html
[5] Office of the Comptroller of the Currency. "GENIUS Act: Anti-Money Laundering/Countering the Financing of Terrorism and Sanctions Compliance: Notice of Proposed Rulemaking." Bulletin 2026-28, June 2026. https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-28.html
[6] US Department of the Treasury. "Treasury Seeks Public Comment on GENIUS Act Notice of Proposed Rulemaking Concerning State-Level Regulatory Regimes." April 2026. https://home.treasury.gov/news/press-releases/sb0428
[7] Consumer Finance Monitor. "Treasury Issues NPRM on State Oversight of Stablecoin Issuers Under the GENIUS Act." April 2026. https://www.consumerfinancemonitor.com/2026/04/14/treasury-issues-nprm-on-state-oversight-of-stablecoin-issuers-under-the-genius-act/
[8] Consumer Financial Services Law Monitor. "Treasury Proposes GENIUS Act Principles for Acceptable State Stablecoin Regimes." April 2026. https://www.consumerfinancialserviceslawmonitor.com/2026/04/treasury-proposes-genius-act-principles-for-acceptable-state-stablecoin-regimes/
[9] Morgan Lewis. "US Stablecoin Regulation: GENIUS Act Implementation and Key Proposals." April 2026. https://www.morganlewis.com/pubs/2026/04/genius-act-implementation-key-proposals-and-what-comes-next
[10] Federal Register. "GENIUS Act Implementation: Advance Notice of Proposed Rulemaking." September 2025. https://www.federalregister.gov/documents/2025/09/19/2025-18226/genius-act-implementation
[11] S.394, GENIUS Act of 2025, Sections 15 and 16. Congress.gov. https://www.congress.gov/bill/119th-congress/senate-bill/394/text
[12] Crypto Times. "GENIUS Act at 10 Months: Stablecoin Rules, Issuer Readiness and State vs Federal Divide." May 2026. https://www.cryptotimes.io/2026/05/18/genius-act-10-months-stablecoin-rulemaking-federal-state-divide/
[13] Forbes. "Banks Suddenly Targeting $323 Billion Stablecoin Market." April 2026. https://www.forbes.com/sites/boazsobrado/2026/04/08/gamechanger-banks-suddenly-targeting-323-billion-stablecoin-market/
[14] Circle. "Circle Submits Comment Letter on Implementation of the GENIUS Act." November 2025. https://www.circle.com/blog/circle-submits-comment-letter-on-implementation-of-the-genius-act
[15] Board of Governors of the Federal Reserve System. "Stablecoins in 2025: Developments and Financial Stability Implications." FEDS Notes, April 2026. https://www.federalreserve.gov/econres/notes/feds-notes/stablecoins-in-2025-developments-and-financial-stability-implications-20260408.html
[16] Reap. "Stablecoin Statistics and Data 2026." July 2026. https://reap.global/blog/stablecoin-statistics-2026
[17] Mordor Intelligence. "Stablecoin Market Size, Share and Growth Trends Report." 2026. https://www.mordorintelligence.com/industry-reports/stablecoin-market
[18] FinanceFeeds. "What Could Push the Stablecoin Market Above $500 Billion?" July 2026, citing EY survey data. https://financefeeds.com/what-could-push-the-stablecoin-market-above-500/
[19] Federal Register. "Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements." April 2026. https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism
