GENIUS Act Deadline Missed, Jan 18 Effective Date Remains Unchanged

The GENIUS Act, signed into law by President Donald Trump in July 2025, is moving toward its January 18, 2027 effective date without a finalized regulatory framework. The act requires federal and state regulators to promulgate regulations within one year of enactment, but the deadline expired on July 18, 2026.

The absence of final rules creates practical problems for companies deciding which licensing route to pursue, how much capital to hold, and which systems must be ready when the law takes effect. Regulators have produced substantial work, with implementation efforts commonly counted at about ten proposal-stage actions.

Treasury began the process in September 2025 with a general implementation notice, while FinCEN and the Office of Foreign Assets Control proposed anti-money-laundering and sanctions requirements for permitted issuers. The OCC issued the broadest package, addressing licensing, reserves, redemption rights, custody, capital, liquidity, reporting, and risk management.

The missed deadline does not invalidate the statute or postpone its requirements, but it shortens the time issuers, banks, and technology providers have to prepare for a regime that may become effective before its capital, liquidity, and supervisory requirements are fully settled.