U.S. financial regulators missed the one-year deadline to finalize regulations implementing the GENIUS Act, leaving key parts of the country’s new federal stablecoin framework incomplete.
Although the law remains in effect, several agencies have yet to issue final rules governing licensing, reserves, custody, reporting, and compliance requirements for payment stablecoin issuers across the United States.
President Donald Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act into law on July 18, 2025, creating the first standalone federal framework for stablecoins.
The legislation established legal standards covering reserve backing, redemption rights, disclosures, licensing, and supervision while directing federal and state regulators to complete implementing regulations within one year through formal rulemaking procedures.
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GENIUS Act Rules Still Await Final Regulatory Approval
Despite the statutory deadline, the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), Treasury Department, Federal Reserve, and federal anti-money laundering authorities have not completed their rulemaking processes.
Most proposals remain under review, while several are still accepting public comments, preventing regulators from issuing legally binding final standards before the required deadline.
The incomplete regulations involve reserve asset requirements, capital requirements, liquidity management, custody standards, redemptions, operational risk management, reporting, customer due diligence, sanctions compliance, and anti-money laundering.
The most recent proposal from the NCUA was released just a day before the deadline, leaving no time for completing the regulatory process through notice and comment period.
In addition, many stakeholders have provided substantial comments which must be taken into consideration prior to completing the framework. BlackRock has requested the OCC to eliminate the 20% cap on the tokenized reserve assets, allow for qualifying Treasury exchange-traded funds to be considered as reserve assets, and increase the range of securities.
Lawmakers and state regulators are now expressing doubts about Treasury’s ability to assess whether a state’s regulatory scheme is substantially similar to federal law.
Stablecoin Industry Prepares Despite GENIUS Act Delay
The delay leaves the stablecoin issuers, banks, credit unions, payment firms, and the state regulators preparing for compliance without finalized regulatory requirements. New York state has already adopted a framework compatible with the GENIUS Act, but may have to revise its approach once the federal agencies will adopt their final rule. Other states await the guidance from the Treasury.
Despite the delay in the rulemaking process, the schedule for the implementation of the GENIUS Act has not been changed. Under section 20, the GENIUS Act will enter into force on either January 18, 2027, or 120 days after all primary federal regulators complete their final implementing rules, whichever comes earlier. Until the implementation date, the stablecoin issuers have to prepare under the existing statutory regime.
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