July 18, 2026 marked one year since President Donald Trump signed the GENIUS Act, the first comprehensive federal framework dedicated to payment stablecoins. However, by the deadline established by Congress, regulators had still not issued the final rules required for the law to become fully operational.
Section 13 of the GENIUS Act required the Office of the Comptroller of the Currency, the Federal Reserve, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the US Treasury and state regulators to complete the rulemaking process within one year of the law’s signing.
In practice, most of the rules remain at the proposal stage:
- The OCC has only published proposed requirements covering reserve assets, capital, liquidity, custody and risk management.
- The FDIC has issued a draft outlining safety standards for stablecoin issuers under its supervision and clarifying how stablecoin reserves should be treated for deposit insurance purposes.
- The NCUA is still collecting feedback on operational requirements for credit unions. Its consultation period ended on July 17, only one day before the statutory deadline, making it almost impossible to complete the process on time.
Several other important rules also remain unfinished:
- Joint customer identification requirements being developed by the Federal Reserve, FinCEN, the OCC, the FDIC and the NCUA remain open for public comment until August 21.
- The FDIC’s proposed rules on anti-money laundering, sanctions compliance and the Bank Secrecy Act remain open for comments until early August.
- The Treasury has not completed the principles for determining when a state regulatory framework is substantially similar to federal standards. This is particularly important for stablecoin issuers with less than $10 billion in circulation that want to remain under state-level supervision.
Companies Have Only Months Left to Prepare
Missing the rulemaking deadline does not delay the GENIUS Act itself. Under Section 20, the stablecoin framework will take effect on January 18, 2027, or earlier if regulators publish all final rules at least 120 days before that date.
After September 20, 2026, even the immediate completion of the rules would push the 120-day transition period beyond January 18, 2027. This means that January 18 has effectively become the default activation date for the GENIUS Act.
In other words, regulatory delays are reducing the amount of time companies have to adjust their systems, reserves and compliance procedures before the law takes effect.
Although the effective date remains unchanged, regulators and market participants have not reached agreement on several important details. During the consultation process, BlackRock asked the OCC to remove the 20% limit on tokenised reserve assets, allow eligible US Treasury bond ETFs to serve as stablecoin backing and expand the permitted reserve pool to include certain floating-rate government securities.
Uncertainty Affects States, Banks and Stablecoin Issuers
The lack of final federal rules is also affecting states that want to retain their own supervisory authority. New York has already started developing stablecoin regulations aligned with the GENIUS Act, including additional limits on reserve assets and stronger risk management requirements.
However, until the federal rules are finalised, New York and other states may need to make further changes before the Treasury officially certifies their frameworks as substantially similar to federal standards.
The dispute has also spread to the traditional banking sector. The American Bankers Association and other financial institutions have urged the OCC, FDIC, Federal Reserve and NCUA to adopt consistent standards across agencies. They argue that inconsistent requirements could allow companies to seek licences from whichever regulator applies the least demanding rules.
At the same time, President Donald Trump has increased pressure on Congress to pass the CLARITY Act, while accusing the banking industry of attempting to block digital asset legislation in order to protect business models based on traditional deposits.
The central provisions of the GENIUS Act have already been enacted and will not change. Stablecoins must be backed 100% by eligible liquid assets, issuers must publish monthly reserve reports, guarantee redemption at a 1:1 ratio and refrain from paying interest directly to stablecoin holders.
The forthcoming rules will mainly clarify how these requirements will be implemented, supervised and enforced, including the penalties that will apply to violations.
Conclusion: the delay increases regulatory uncertainty for banks, stablecoin issuers and cryptocurrency companies, which will now have less time to prepare for the new requirements. Large institutions with established compliance infrastructure may gain an advantage, while smaller issuers and companies operating across several states could face higher costs and the risk of inconsistent supervisory standards.
