Ten days remain before the statutory deadline for federal agencies to publish the implementing rules under the GENIUS Act. As of this week, the rulebook is still missing, leaving stablecoin issuers to prepare against proposed texts rather than binding regulations.
Seven federal agencies — the OCC, FDIC, Federal Reserve, NCUA, Treasury, FinCEN and OFAC — are required to complete the stablecoin rulemaking by July 18, one year after the law was signed.
Between December 2025 and June 2026, they released proposals covering capital, reserves, liquidity, redemption, financial crime compliance and credit union-affiliated issuers.
The drafts do not settle the details, but they show the direction of the first federal stablecoin regime: higher capital and liquidity standards, tighter reserve rules, and bank-style compliance obligations for issuers.
The Rulebook is Still in Draft, but the Outline Is Already Clear
The Office of the Comptroller of the Currency (OCC) published the most detailed proposal in February, setting out how federally supervised stablecoin issuers would be licensed, examined and required to manage reserves and redemptions.
In the following months, other agencies filled in separate parts of the framework: bank-affiliated issuers, state regime certification, anti-money laundering controls and sanctions compliance. Comments on the main proposals closed by June 9.
The National Credit Union Administration (NCUA) came later than the other agencies: its proposal for credit union-affiliated stablecoin issuers was published in May, and the comment period closes on July 17, one day before the deadline.
The Federal Reserve has not published a standalone proposal for stablecoin issuers under its supervision, joining only the interagency customer identification proposal released in June. That leaves subsidiaries of state member banks without the same agency-specific roadmap that OCC- and FDIC-supervised issuers already have.
What Issuers Will Have to Comply With
Every permitted issuer must hold 1:1 reserves in eligible assets. Rehypothecation of those reserves is prohibited for most purposes. Issuers must publish monthly reserve reports certified by the CEO and CFO with third-party attestation.
Issuers become financial institutions under the Bank Secrecy Act. The FinCEN and OFAC proposal spells out board-approved AML programmes, suspicious activity reporting, sanctions screening, and the ability to block or freeze tokens when required by law. FinCEN estimates the rules would initially apply to around 50 issuers.
The OCC has proposed a $5 million minimum capital floor for new federal issuers. Eligible reserve assets would include cash, balances at Federal Reserve Banks, insured demand deposits, Treasury bills, and overnight Treasury repos.
Under the OCC’s quantitative option, at least 10 percent of outstanding stablecoins would need to be redeemable on the same business day, and at least 30 percent within five business days. Redemption at par within two business days of a valid request. Under stress conditions exceeding 10 percent of outstanding issuance over 24 hours, issuers would have up to seven calendar days.
The Compliance Clock Starts Later Than July 18
July 18 is a deadline for regulators, not for issuers. Under the GENIUS Act, the framework becomes effective 120 days after the primary federal regulators publish their final rules, or on January 18, 2027, whichever comes first.
Some requirements follow their own timetable. FinCEN and OFAC AML rules give issuers 12 months to implement compliance programmes. From July 18, 2028, exchanges, brokers and custodians will no longer be allowed to offer stablecoins in the US unless issued by a permitted domestic or registered foreign issuer.
Not Every Issuer Starts From the Same Position
Circle and Paxos received conditional national trust bank charters from the OCC in December 2025. Ripple has applied but its application has yet to be approved. Tether’s USDT reserves include asset classes outside the proposed eligible list. Tether launched USA₮ through Anchorage Digital Bank in January 2026.
Treasury’s framework for certifying state regimes as “substantially similar” to federal standards remains in proposed form; no state has yet been certified.
What to Watch After July 18
The next phase will depend first on whether regulators meet the July 18 deadline at all. If they do, focus shifts to final text: whether the OCC keeps its quantitative liquidity option, how reserve diversification is handled, and whether the Federal Reserve closes the gap for issuers under its supervision.
Once the primary federal regulators publish the final rules, the 120-day clock begins.