GENIUS Act Stablecoin Rules Take Shape Amid Regulatory Uncertainty

The GENIUS Act, passed in July 2025, has been making headlines for its framework on payment stablecoins, but many readers wonder what actually applies today. The answer is that the statute on its own doesn't create a finished, workable market; implementing rules are needed to translate statutory guardrails into operational requirements. These rules cover authorisation, reserves, reporting, capital, liquidity, and risk management.

The current legal status is as follows: the statute applies in principle 18 months after enactment, or 120 days after final rules from primary federal regulators, whichever comes first. As matters stand today, January 18, 2027 is the central statutory reference point.

The US Treasury plays a central role in giving the federal framework practical shape. Its procedures are not merely communication but genuine rulemaking steps. The Treasury proposal published on August 17, 2026 is a draft rule, not law in final force. It deals with central questions of scope: when does a payment stablecoin count as issued in the United States?

The Office of the Comptroller of the Currency (OCC) has also published a draft rule, focusing on capital and liquidity requirements, operational risk, governance, and ongoing supervision. The OCC intends to publish a final GENIUS Act rule by November 2026.