The GENIUS Act deadline missed by US regulators on 18 July 2026 leaves the federal stablecoin framework short of the implementing rules Congress required, with the January 2027 effective date now the next hard stop on the clock.
President Donald Trump signed the GENIUS Act into law on 18 July 2025. The statute required primary federal payment stablecoin regulators to issue implementing rules within one year. That window closed with several major rule packages still at the proposal stage.
What Passed the Deadline Still Open
The Office of the Comptroller of the Currency (OCC) published its proposed GENIUS Act rules in February under Docket ID OCC-2025-0372. The framework covers reserve assets, redemptions, capital, liquidity, custody and risk management for issuers under OCC supervision. Comptroller Jonathan V. Gould said the agency ‘has given thoughtful consideration to a proposed regulatory framework in which the stablecoin industry can flourish in a safe and sound manner.’ Final rules were not in place by the deadline.
The Federal Deposit Insurance Corporation (FDIC) has actually run two separate GENIUS Act rulemakings. The first, issued on 19 December 2025, covers application procedures for insured state non-member banks and state savings associations seeking approval to issue payment stablecoins through a subsidiary. The second, proposed in April 2026, sets out the prudential framework: reserve requirements, capital, redemptions, custody and risk controls for issuers linked to FDIC-supervised institutions. Neither is final.
The FDIC’s prudential proposed rule would require Permitted Payment Stablecoin Issuers (PPSIs) to maintain clearly identifiable reserves that fully back total outstanding issuance at all times, with reserve asset value meeting or exceeding outstanding issuance value. It would also clarify that payment stablecoin reserves held as bank deposits would not receive pass-through deposit insurance, while tokenised deposits satisfying the statutory definition of ‘deposit’ would retain standard coverage.
As of Q3 2025, the FDIC supervises 2,778 insured depository institutions, of which 2,064 are classified as small, representing the pool potentially subject to its GENIUS Act stablecoin rules across both proposals.
AML, Sanctions and the GENIUS Act Deadline Missed on Customer Identification
Anti-money laundering and sanctions requirements are further behind. The OCC’s proposed rule explicitly excludes Bank Secrecy Act, AML and OFAC sanctions requirements, noting these will be addressed in a separate rulemaking coordinated with the Treasury Department.
That coordinated rulemaking arrived via a joint proposed rule from FinCEN and the Office of Foreign Assets Control (OFAC). It would require PPSIs to adopt and maintain an effective sanctions compliance programme in addition to BSA anti-money laundering obligations. The public comment period on the joint proposal runs past the 18 July deadline, meaning the normal review-to-finalisation sequence cannot be completed before the framework’s scheduled start.
A separate joint federal proposal would require covered issuers to verify customers and maintain identification records, treating permitted stablecoin issuers as financial institutions under Bank Secrecy Act requirements. That too remains open.
State certification is similarly unsettled. The Treasury proposed rules in April for determining whether state frameworks qualify as ‘substantially similar’ under the GENIUS Act, but that certification process has not been finalised. A bipartisan group of senators has urged Treasury to protect the role of state regulators and provide clearer timelines. New York has moved to align its framework with federal standards ahead of seeking recognition under the Act.
The Effective Date Mechanic and What Issuers Face
Missing the rulemaking deadline does not shift the Act’s start date. According to the OCC’s proposed rulemaking, the GENIUS Act takes effect on the earlier of 18 months after enactment (putting the outer limit at 18 January 2027) or 120 days after primary federal regulators issue their final implementing regulations. That 120-day trigger means regulators could still compress the preparation window if they move quickly on final rules.
The OCC’s proposed rule estimated stablecoin market cap at $250 billion at enactment, projecting growth to $500 billion in 2026, $1 trillion in 2027, and $2 trillion in 2028 (the last figure citing a Standard Chartered projection reported by Bloomberg on 15 April 2025). Issuers preparing at that scale face a moving target: reserve management, customer onboarding, redemption processes and compliance infrastructure all need calibration against rules that are not yet final.
Major banking groups had already asked regulators to coordinate the various GENIUS Act proposals rather than finalise them separately, given the close interdependencies across agency frameworks. With most of those frameworks still open past the statutory deadline, the pressure for that coordination has only increased.
