The GENIUS Act gave US regulators one year to turn Congress’s federal stablecoin framework into an operational rulebook. That deadline passed on July 18, 2026, with no final implementing regulations in place.
Section 13 of the GENIUS Act directed every primary federal payment stablecoin regulator, the Treasury Department and each state payment stablecoin regulator to implement the law through notice-and-comment rulemaking within one year of enactment. President Donald Trump signed the Act on July 18, 2025, making July 18, 2026 the statutory deadline.
Nothing automatic happened when that date passed. Section 13 does not contain a penalty clause, substitute rules or an enforcement mechanism that completes the framework when regulators miss the timetable. The agencies remain responsible for finishing the work, while issuers continue preparing around proposals that can still change.
Regulators have produced a substantial body of draft regulation. Roughly ten proposed rules have emerged across the OCC, FDIC, Treasury, FinCEN, Federal Reserve and National Credit Union Administration, but none had been finalized by the deadline. The result is not a legal vacuum because the statute already establishes the broad regime. It is an implementation gap involving the capital, liquidity, redemption, licensing and financial-crime requirements companies will need to follow in practice.
What Section 13 Required by July 18
The GENIUS Act established the structure of the new regime in legislation. Payment stablecoins must generally be issued by permitted issuers, supported by eligible reserves and redeemable at a fixed monetary value. Issuers will face disclosure, supervisory, risk-management and financial-crime requirements, while digital asset platforms will eventually face restrictions on offering stablecoins that do not meet the federal framework.
Congress left regulators to determine how many of those requirements would operate. Section 13 required the relevant federal and state authorities to promulgate implementing regulations within one year. The requirement was therefore to complete appropriate rulemaking, not merely publish proposals or open consultations.
The distinction matters because a proposed regulation is not a final compliance standard. Capital formulas, reserve composition, liquidity thresholds, redemption procedures, application requirements and supervisory reporting can all change after agencies review public comments.
FinanceFeeds previously examined the Treasury rollout of the GENIUS Act framework. The missed deadline now shows that the transition from legislation to enforceable supervision is taking longer than Congress prescribed.
Where the Main Regulators Stand
The Office of the Comptroller of the Currency issued a broad proposed rule on February 25 covering most of the regulations it must administer under the GENIUS Act. The proposal addresses eligible reserves, capital, liquidity, redemptions, risk management, audits, custody, applications, supervision and foreign issuers. The OCC said the remaining Bank Secrecy Act, anti-money laundering and sanctions provisions would be handled through separate coordinated rulemaking.
Under the OCC proposal, certain federally supervised nonbank stablecoin issuers would face a minimum capital floor of $5 million. For liquidity, the agency proposed two alternative approaches rather than a three-tier regulatory framework.
One is a principles-based option supported by a regulatory safe harbour. The other imposes quantitative reserve-liquidity requirements. Within that quantitative option, at least 10% of required reserve assets would have to be held in demand deposits or balances at a Federal Reserve Bank. Further portions would need to be available over longer periods, subject to maturity restrictions and a weighted-average-maturity limit.
The 10% figure is a reserve-composition requirement. It does not require issuers to redeem 10% of outstanding stablecoins on the same business day.
The OCC separately proposed a general two-business-day redemption standard. When redemption requests exceed 10% of an issuer’s outstanding stablecoin value during a 24-hour period, the permitted window would extend to seven calendar days. The distinction matters because the threshold provides extra time during unusually large redemption events rather than imposing faster redemptions.
The FDIC proposed a similar prudential framework for issuers connected to institutions under its supervision. Its April rule covers reserves, capital, risk management, custody and redemption, and would also generally require stablecoins to be redeemed within two business days.
Treasury has proposed rules addressing state regulatory regimes and illicit-finance obligations. Its state-regime process will determine whether a state framework is substantially similar to the federal system, a designation that can allow qualifying issuers with no more than $10 billion in outstanding payment stablecoins to remain primarily under state supervision.
FinCEN, the Federal Reserve, the OCC, the FDIC and the NCUA have also participated in joint proposed customer-identification requirements for stablecoin issuers. That consultation remains open until August 21, more than one month after the statutory implementation deadline.
The Federal Reserve and NCUA therefore remain part of the unfinished framework even though they have attracted less attention than the OCC and FDIC. Both are primary federal payment stablecoin regulators for entities within their respective jurisdictions, and both are participating in rule packages that had not become final by July 18.
The Missed Deadline Does Not Move the Effective Date
The GENIUS Act takes effect on the earlier of January 18, 2027, which is 18 months after enactment, or 120 days after the primary federal payment stablecoin regulators issue final regulations implementing the Act.
The missed rulemaking deadline therefore does not automatically give issuers more time. January 18 remains the statutory backstop. The delay instead reduces the period available between publication of the final rules and the date on which the federal regime becomes operative.
If the primary regulators had completed the rules substantially before September, the 120-day mechanism could have activated the Act before January 18. Final regulations issued after approximately September 20 would generate a 120-day date on or after the statutory backstop, making January 18 the earlier trigger.
The practical consequence is a compressed preparation period. Issuers may receive final details covering capital, reserve management, redemptions and supervision only weeks or months before they must begin operating under the regime.
Issuers Are Building Around Proposals
Stablecoin companies are not waiting for every regulation to be finalized. Existing issuers are adjusting reserve practices, compliance systems and corporate structures, while banks and crypto firms are developing products intended to fit the federal framework.
Tether launched USA₮ through Anchorage Digital Bank as a separate US-focused stablecoin rather than attempting to place its global USDT product directly inside the new system. The token’s supply later rose nearly 540% in April, providing an early indication of demand for products designed around US regulatory expectations.
Other firms must decide whether to seek federal approval, operate through a qualifying state regime or partner with an already regulated institution. Those decisions depend on unresolved questions involving capital calculations, reserve liquidity, custody, customer identification, redemption procedures and supervisory costs.
The Realistic Timeline Now
The likely outcome is a sequence of final rules over the remaining months of 2026 rather than one coordinated rulebook issued on a single date. Prudential requirements may be completed separately from customer-identification, sanctions and state-certification regulations.
The missed deadline does not invalidate the GENIUS Act, punish the agencies or fill the unfinished parts of the framework. It leaves companies preparing for a January 2027 backstop while several of the rules governing their operations remain provisional.
Congress has decided what the US stablecoin market should broadly look like. Regulators missed the deadline for explaining exactly how companies must operate inside it.
