US Regulators Miss the GENIUS Act Rulemaking Deadline
July 18, 2026 marked one year since President Donald Trump signed the GENIUS Act into law. The legislation established the first comprehensive US federal regulatory framework specifically for payment stablecoins.
Section 13 of the GENIUS Act required each primary federal payment stablecoin regulator, the US Treasury and each state payment stablecoin regulator to promulgate implementing regulations no later than one year after the law was enacted.
However, as of the article’s publication on July 20, no complete set of final implementing regulations had been issued. Several major parts of the framework remained at the proposal or public-comment stage:
- The Office of the Comptroller of the Currency had proposed broad rules covering reserve assets, redemption, capital, liquidity, custody, risk management, applications and supervision, but had not issued a final rule.
- The Federal Deposit Insurance Corporation had proposed prudential standards for issuers under its supervision, including rules for reserves, redemption, capital and risk management. Its separate proposal covering Bank Secrecy Act and sanctions compliance remained open for comments until August 4.
- The National Credit Union Administration’s comment period on operational and risk-management standards ended on July 17, only one day before the statutory deadline. A final rule had not been issued by July 18.
- Joint customer identification requirements proposed by FinCEN, the Federal Reserve, the OCC, the FDIC and the NCUA remained open for public comment until August 21.
- The Treasury had proposed principles for determining whether state regulatory frameworks are substantially similar to the federal regime, but those principles had not yet been finalised.
Companies Have Only Months Left to Prepare
Missing the rulemaking deadline does not suspend the GENIUS Act or automatically postpone its effective date.
Under Section 20, the legislation takes effect on the earlier of January 18, 2027 — 18 months after enactment — or 120 days after the primary federal payment stablecoin regulators issue final regulations implementing the Act.
September 20, 2026 is exactly 120 days before January 18, 2027. Therefore, if qualifying final regulations are issued after September 20, January 18 will remain the earlier of the two statutory dates.
This leaves stablecoin issuers, banks, custodians and other market participants with a fixed outside date for compliance but without all the final operational details needed to adjust their systems, reserve structures and internal procedures.
Industry comments also show that significant parts of the proposed framework remain contested. In May, BlackRock urged the OCC not to introduce an additional 20% cap solely because eligible reserve assets are held in tokenised form. The asset manager also asked the regulator to confirm that qualifying ETFs investing exclusively in eligible reserve assets may be used as stablecoin reserves and to approve certain US Treasury floating-rate notes with remaining maturities of up to two years.
Uncertainty Affects States, Banks and Stablecoin Issuers
The absence of final federal rules also affects states seeking to retain supervisory authority over payment stablecoin issuers.
Under the GENIUS Act, issuers with no more than $10 billion in consolidated outstanding issuance may opt for state-level supervision, provided that the applicable state framework is determined to be substantially similar to the federal regime.
New York has already proposed stablecoin regulations intended to align its existing framework with the GENIUS Act. The proposal incorporates requirements for eligible reserves, redemptions, audits, risk management and limits on the concentration of reserve assets held with individual custodians.
However, changes to final federal regulations could require New York and other states to revise their own rules before their frameworks can be certified.
Differences between federal agencies or state regimes could also create opportunities for regulatory shopping, with issuers preferring the jurisdiction that applies the least burdensome interpretation of the law.
The possible effects of stablecoin growth on traditional financial institutions remain disputed. FORECK.INFO previously examined this issue in an article explaining why the risks posed by stablecoins to bank lending may be smaller than industry estimates suggest.
The rulemaking delay is unfolding alongside a separate dispute over stablecoin rewards and the broader CLARITY Act. FORECK.INFO also reported on efforts by US senators to reach a compromise between the banking and cryptocurrency industries.
Core Stablecoin Requirements Are Already Set by Law
Although many implementation details remain unfinished, the GENIUS Act itself already establishes the main statutory requirements for permitted payment stablecoin issuers.
Issuers must maintain identifiable reserves backing their outstanding stablecoins on at least a one-to-one basis using eligible liquid assets. They must also publish the monthly composition of their reserves and clearly disclose their redemption policies and associated fees.
The Act prohibits permitted issuers from paying holders interest or yield solely in connection with holding, using or retaining a payment stablecoin.
The final rules are expected to provide more detailed standards covering licensing, capital, liquidity, custody, operational risk, cybersecurity, customer identification, anti-money laundering controls, sanctions compliance, state certification, supervision and enforcement.
Conclusion: the missed deadline does not prevent the GENIUS Act from taking effect, but it compresses the time available for companies to prepare. Large institutions with established compliance and reserve-management infrastructure may be better positioned to absorb the changes, while smaller issuers and companies operating across multiple states could face higher costs and greater regulatory uncertainty.
