The GENIUS Act: the US payment stablecoin rulebook

The GENIUS Act is the first comprehensive US federal framework for payment stablecoins: who may issue them, what must back them, and which regulator supervises the issuer. Signed on 18 July 2025, it requires reserves of at least 1:1 in high-quality liquid assets, monthly public reserve disclosures, redemption at par, full Bank Secrecy Act compliance, and a flat prohibition on paying holders interest or yield.

One year on, the statute’s second act has a verdict: the law told regulators to issue implementing rules by 18 July 2026, and the deadline passed with every major package still a proposal. The regime’s effective date is unmoved. This guide covers what the Act itself says, where the rulemaking stands, and what the regime means for institutions that issue, hold, or settle in stablecoins.

What the GENIUS Act requires

The Act defines a payment stablecoin as a digital asset designed to hold a stable value against a fixed monetary amount and used for payment or settlement. For issuers, the core obligations are:

• Reserves. At least one dollar of reserve assets for every dollar of stablecoins outstanding, held in US coins and currency, insured deposits, Treasury bills, Treasury-backed repurchase agreements, government money market funds, and similar narrow instruments. Reserves cannot be pledged or rehypothecated except in limited cases the Act specifies.
• Disclosure and certification. Monthly published reports on the composition of reserves, examined by a registered public accounting firm, with CEO and CFO certifications. Knowingly false certification carries criminal exposure.
• Redemption. Issuers must maintain and publish clear policies for timely redemption at par.
• No yield. Permitted issuers may not pay holders interest or any other form of return on the stablecoin itself.
• Financial crime controls. Issuers are treated as financial institutions under the Bank Secrecy Act, with sanctions and anti-money-laundering program obligations that Treasury, FinCEN, and OFAC are detailing in rulemaking.

Who may issue

The Act creates three permitted-issuer routes. A subsidiary of an insured depository institution may issue, supervised by the parent bank’s primary federal regulator. A nonbank may apply to the OCC as a federal-qualified issuer. And a state-qualified issuer may operate under a state regime certified as substantially similar to the federal one, so long as its outstanding stablecoins stay under $10 billion, after which it must move to federal supervision. The Act also restricts US offering of foreign-issued stablecoins to issuers from jurisdictions with comparable regimes, subject to Treasury determinations.

The practical consequence: US-facing stablecoin issuance is becoming a chartered, examined activity. What the market treated for a decade as a disclosure question is now a licensing question, for issuers. The Act’s licensing targets are issuers. Institutions that hold or settle in stablecoins inherit its effects at one remove: a cleaner counterparty-risk picture, standardized reserve disclosures, and a shrinking excuse for treating stablecoin exposure as unanalyzable.

Where the rulemaking stands (July 2026)

The statute set a one-year deadline for implementing regulations: 18 July 2026. The proposals arrived through the spring:

Date	Step
18 Jul 2025	GENIUS Act signed into law
25 Feb 2026	OCC proposes rules for federal-qualified nonbank issuers: applications, permissible activities, reserves, redemption, risk management, and a capital floor
Mar-Apr 2026	FDIC proposals covering licensing and substantive standards for FDIC-supervised issuers; NCUA proposal for credit-union-affiliated issuers
Spring 2026	Treasury, FinCEN, and OFAC jointly propose the AML, CFT, and sanctions compliance program rules
5-22 Jun 2026	Late proposals arrive: the FDIC’s BSA and sanctions standards (comments to 4 Aug) and the joint customer identification rule (comments to 21 Aug)
18 Jul 2026	Statutory deadline passes with no final rules published
18 Jan 2027	Effective date. The statute’s formula is the earlier of 18 months after enactment or 120 days after final rules; with the finals late, the backstop governs

The deadline was missed. Every major package from the OCC, FDIC, NCUA, and Treasury remained a proposal on 18 July 2026, and two comment periods were still open on the deadline itself, which made timely finals impossible through the ordinary notice-and-comment process. The miss carries no statutory penalty and does not delay the regime: the law takes effect on 18 January 2027 regardless, leaving a compressed window between whatever finals emerge and the start line. The full agency-by-agency record is in our rulemaking scorecard, which we update as finals publish.

What institutions should be doing

None of this is legal advice; the questions below are the ones worth putting to counsel and to your regulator early.

• Banks have the clearest new option: issuing through a subsidiary under their existing primary regulator, or serving the market as reserve custodians and redemption banks. The strategic fork between issuing a stablecoin and tokenizing deposits is covered in what the GENIUS Act means for banks.
• Payment providers, exchanges, and platforms should map which of the coins they touch will be issued by permitted issuers once the regime is effective, and what happens to flows that rely on coins that will not qualify for US offering.
• Enterprises and treasuries gain a standardized disclosure regime for assessing issuer risk: monthly attested reserve reports replace the patchwork of voluntary attestations.
• Everyone now has a fixed date to plan against: 18 January 2027. The open question is no longer when the regime starts but how close to the start line the final rules land.

Where Frame fits

Frame is the settlement layer for global finance: one integration to orchestrate payments at scale across fiat rails, stablecoins, and tokenized deposits, with compliance enforced on every transaction and settlement in seconds instead of days.

The GENIUS Act makes coin eligibility a regulatory property that changes over time: which issuers are permitted, which foreign coins may be offered, what a compliant US settlement leg looks like. Frame is rail-neutral, and within the stablecoin rail it is coin-neutral, so those determinations live in policy rather than in code. Frame’s Rules Engine evaluates every transaction against its governing policies, including which instruments a given flow may settle in and in which jurisdiction; when the rules change, the policy changes, and the integration does not. A transfer that cannot satisfy its policy does not settle, and every settled transaction produces verifiable evidence that its conditions were met.

See how rail-neutral settlement works in practice: The Frame Blueprint.