Six federal agencies have 28 days to finalize rules implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act, signed into law on July 18, 2025. The statutory clock expires on July 18, 2026. As of June 20, every major rule remains in proposed form. The Federal Reserve...
"The July 18 deadline is real, but the idea that all six agencies will have final rules by then is not." — Chapman and Cutler LLP, GENIUS Act Rulemaking Tracker
Six federal agencies have 28 days to finalize rules implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act, signed into law on July 18, 2025. The statutory clock expires on July 18, 2026. As of June 20, every major rule remains in proposed form. The Federal Reserve Board has not issued a single proposed rule.
The GENIUS Act created the first federal licensing and prudential framework for payment stablecoins, a market now exceeding $320 billion in circulating supply. The OCC, FDIC, NCUA, Treasury, FinCEN, and OFAC have collectively issued more than a dozen proposed rules, consultations, and reporting templates over the past 11 months. Comment periods have closed. Final rules have not appeared.
The base case, according to legal trackers and regulatory counsel, is a deadline miss followed by interim rules, with final regulations landing in late 2026 or early 2027. The January 18, 2027 backstop — 18 months after enactment — remains the more realistic activation date.
The GENIUS Act passed the Senate 68-30, with 18 Democrats joining 50 Republicans. The House followed with a 308-122 vote. President Trump signed it on July 18, 2025. It is the first major federal crypto legislation enacted in the United States.
The law establishes the "permitted payment stablecoin issuer" (PPSI) category. Only PPSIs — entities licensed at the federal or state level — may legally issue payment stablecoins in or into the United States. Non-financial public companies are prohibited from serving as issuers unless they receive unanimous approval from the newly created Stablecoin Certification Review Committee (SCRC).
The Act's effective date is the earlier of 18 months after enactment (January 18, 2027) or 120 days after agencies issue final implementing regulations. In practice, if final rules emerge by September 2026, the Act could take effect by January 2027 regardless. If rules miss the statutory deadline, the 18-month backstop governs.
A three-year transition period gives the market time to adjust: until July 2028, existing stablecoins issued by non-PPSIs can continue circulating.
Seven agencies share rulemaking duties. Their progress varies.
Office of the Comptroller of the Currency (OCC). Published its proposed rule on March 2, 2026, covering the central federal framework for issuers under OCC jurisdiction. The comment period closed May 1. The proposal sets a $5 million minimum capital floor for new issuers, requires 10% of reserves to be held as immediately available liquidity (demand deposits or Federal Reserve Bank balances), and mandates that issuers with $25 billion or more in outstanding stablecoins hold 0.5% of that balance in insured deposits, capped at $500 million. For issuers exceeding $50 billion in circulation, annual GAAP-compliant audits by a registered public accounting firm are required. Status: proposed.
Federal Deposit Insurance Corporation (FDIC). Approved its notice of proposed rulemaking on April 7, 2026, establishing prudential standards for FDIC-supervised PPSIs and insured depository institutions engaged in stablecoin activities. The FDIC also published a separate proposal for GENIUS Act application procedures in December 2025. Comment periods for the April proposal closed June 9. Status: proposed.
Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC). Published a joint notice of proposed rulemaking on April 10, 2026, creating Part 1033 of 31 C.F.R. chapter X — a stand-alone BSA framework for PPSIs. The rule would treat stablecoin issuers as financial institutions under the Bank Secrecy Act and require them to maintain sanctions compliance programs. Comments closed June 9. Status: proposed.
U.S. Treasury. Opened consultations on state-regime "substantial similarity" standards and foreign issuer equivalency determinations. The Treasury comment period on state-regime standards closed June 2. No proposed rule for foreign issuer access has been published. Status: consultation phase.
National Credit Union Administration (NCUA). Began building a credit-union issuer framework. Comment period closes July 17, 2026 — one day before the statutory deadline. Status: proposed.
Federal Reserve Board. Has not issued a proposed rule. The Fed retains supervisory authority over banking entities within its jurisdiction that seek to issue stablecoins. Its silence is the most consequential gap in the rulemaking timeline.
The GENIUS Act's substantive requirements span reserve management, redemption, disclosure, and anti-money laundering.
Reserve backing. One-to-one reserves are mandatory. Permitted reserve assets include U.S. dollars, demand deposits at insured depository institutions, short-term U.S. Treasury securities, repurchase agreements backed by Treasuries, and other liquid assets approved by the primary federal regulator. Reserves must be segregated and identifiable.
Redemption. Issuers must redeem stablecoins within two business days of a holder's request. Redemption policies must be publicly disclosed.
Interest prohibition. PPSIs may not represent that their stablecoins pay interest or yield. Returns on reserve assets accrue to the issuer, not the token holder. The Bank Policy Institute has publicly contested this provision, arguing in comment letters that prohibiting interest payments creates a competitive advantage for nonbank issuers over banks, which are subject to Regulation Q.
Disclosure. Monthly reserve composition reports are required. Issuers above $50 billion in circulation must publish annual GAAP audits.
AML/CFT. PPSIs must establish and maintain BSA-compliant anti-money laundering programs, file suspicious activity reports, and implement customer identification programs. The FinCEN/OFAC proposed rule would make these the first sanctions compliance programs mandated by U.S. statute for a crypto-adjacent entity class.
Tether's USDT, with $186.5 billion in circulation as of June 17, 2026, represents 58% of the stablecoin market. Tether is domiciled in El Salvador. USDT does not meet GENIUS Act PPSI requirements.
Under the Act, foreign issuers require a Treasury equivalency determination to continue serving U.S. businesses. As of June 20, 2026, that determination has not been issued. Treasury has not published a proposed rule for foreign issuer access. The three-year transition period (expiring July 2028) provides a buffer, but the lack of any regulatory framework for foreign issuers creates material uncertainty for U.S. operators whose settlement infrastructure depends on USDT.
Tether's response: a separate, compliant token. On January 27, 2026, Tether launched USAT (USA₮), issued by Anchorage Digital Bank, N.A. — an OCC-regulated, federally chartered digital asset bank. Cantor Fitzgerald serves as reserve custodian and primary dealer. USAT launched with support from Kraken, OKX, Bybit, Crypto.com, and MoonPay.
USAT and USDT maintain separate reserves, separate issuance mechanics, and separate regulatory regimes. The architecture effectively partitions Tether's empire into a regulated U.S. entity and a global offshore operation. Whether this dual structure satisfies the Act's intent remains an open question for regulators.
The $320 billion stablecoin market is recomposing around regulatory lines.
Circle (CRCL). The company IPO'd on the NYSE on June 5, 2025 at $31 per share. As of June 18, 2026, shares trade at $80.59. Q1 2026 revenue reached $694 million; adjusted EBITDA was $151 million at a 53% margin. TTM revenue stands at $2.7 billion. Circle received a conditional national trust bank charter from the OCC in December 2025. USDC's circulating supply is $75.8 billion, representing 24.4% market share — a 220% increase from late 2023. The GENIUS Act's compliance architecture aligns with Circle's existing structure: 1:1 reserves, monthly attestations, SEC reporting obligations.
Bank entrants. The OCC framework opens a path for national banks and their subsidiaries to issue payment stablecoins directly. JPMorgan already operates JPM Coin. The Bank Policy Institute, The Clearing House, and the Consumer Bankers Association submitted joint comments on June 9 arguing that the FDIC's proposed rule should ensure competitive parity between bank and nonbank issuers. Banks want to issue stablecoins under the same framework — but with their existing deposit insurance and Federal Reserve access intact.
State-licensed issuers. The GENIUS Act authorizes state regulation of nonbank issuers below $10 billion in outstanding issuance, provided the state's regime is "substantially similar" to the federal framework. Treasury has solicited comments on what "substantially similar" means. Several states — including Wyoming, which has already chartered stablecoin issuers under its Special Purpose Depository Institution framework — are lobbying for broad equivalency recognition.
According to Chapman and Cutler LLP's GENIUS Act Rulemaking Tracker and CryptoTimes analysis, seven policy gaps remain open as of June 19:
State regime qualification. Treasury has not finalized standards for determining when a state's regulatory regime qualifies as "substantially similar." States with existing frameworks — Wyoming, New York — need clarity.
Foreign issuer access. No proposed rule exists. Tether's USDT, representing $186.5 billion in circulation, operates without a defined pathway to compliance. The Treasury equivalency determination is the single largest outstanding regulatory question.
Redemption stringency. The two-business-day redemption window is specified in statute, but operational details — dispute resolution, partial redemption, cross-chain redemption mechanics — remain unaddressed.
Reserve quality and custody verification. Regulators have not specified acceptable custodians for non-cash reserve assets or standardized verification protocols across agencies.
Customer identification across distribution models. Stablecoins circulate through exchanges, wallets, DeFi protocols, and peer-to-peer transfers. FinCEN's proposed CIP requirements do not clearly address downstream distribution.
Yield and deposit-like incentives. The Act prohibits interest payments on stablecoins, but DeFi protocols routinely offer yield on stablecoin deposits through lending markets. Enforcement boundaries are undefined.
Effective date mechanics. If agencies issue final rules at different times, which agency's publication triggers the 120-day countdown? The statute is ambiguous.
The GENIUS Act represents the first federal attempt to bring $320 billion in stablecoin supply under a unified regulatory framework. Eleven months of rulemaking have produced a substantial body of proposed rules, but no final rules. The most consequential gap — foreign issuer access — directly implicates the largest single asset in the market (USDT at $186.5 billion).
The regulatory architecture, once finalized, will likely bifurcate the stablecoin market into a regulated domestic tier (USDC, USAT, bank-issued coins) and an offshore tier (USDT) operating under a transitional exemption. Whether that transition ends in integration or exclusion depends on Treasury's equivalency determination — a document that, as of June 20, 2026, does not exist in draft form.
Market participants operating on the assumption that the July 18 deadline will produce a complete rulebook should plan for a partial outcome. The infrastructure is being built. The deadline will not be met.