The GENIUS Act at One Year: Still No Final Stablecoin Rules
A year after the GENIUS Act became law, US regulators missed the mark to finalise stablecoin rules — ten proposals, none final. What the limbo means for issuers and settlement.
Contents
A year ago the United States finally passed a federal stablecoin law, and the industry treated it as the moment American digital-dollar rules stopped being a patchwork. Twelve months later the law is still on the books and still not operable. President Trump signed the GENIUS Act on 18 July 2025; by its first anniversary the agencies had produced a stack of proposed rules and finalised exactly none of them. The statute exists — the machinery that makes it enforceable does not.
- The GENIUS Act — the first comprehensive US federal framework for payment stablecoins — was signed 18 July 2025, but a year on the implementing rules are still proposals, not law.
- Agencies issued proposed rules across four bodies — four from Treasury, two from the OCC, one from the FDIC, plus an NCUA path for credit unions — and none were finalised by the one-year mark.
- The Act takes effect on the earlier of 18 months after enactment (January 2027) or 120 days after final rules. With no finals, the 120-day clock has not started.
- The operational core — foreign-issuer registration and state/federal equivalence — remains in draft, leaving US issuers in a defined-but-not-enforceable limbo.
- Contrast: EU MiCA went from law to a hard, enforced deadline. Don’t wait on US finality — anchor licensing and settlement in a regime with operable rules today.
Signed is not the same as effective
The clickbait framing doing the rounds is that the GENIUS Act “failed.” That is the wrong read, and it matters to get it right, because the distinction changes what an operator should do. The law did not fail — it passed, cleanly, and it remains valid federal law. What has not happened is the rulemaking that turns a statute into a set of requirements a firm can actually build against.
The effective-date mechanics are the whole story. The Act takes effect on the earlier of two triggers: 18 months after enactment, or 120 days after the primary federal regulators issue final rules. Eighteen months from 18 July 2025 lands in January 2027. The 120-day path was meant to be the faster one — finalise the rules, start a four-month countdown, done. But that countdown only begins when final rules exist, and a year in there are none. So the fast route is closed by inaction, and the industry is left waiting on a backstop date that is still months away.
An NPRM — notice of proposed rulemaking — signals what an agency is minded to do and invites comment. It binds no one. Building your compliance programme around the text of a proposal is a bet that nothing changes between draft and final, and on foreign-issuer registration and state equivalence, those are exactly the provisions most likely to move. Until a rule is finalised, treat it as direction of travel, not a standard.
Plenty of proposals, zero final rules
The volume of activity is easy to mistake for progress. Four agencies have been busy, and the count reflects it — but a proposal is not a finished rule, and none of these had crossed that line at the one-year mark.
| Agency | Proposals issued | What they cover |
|---|---|---|
| US Treasury | Four | Overall implementation, state/federal equivalence criteria, foreign-issuer registration, and AML provisions |
| OCC | Two | Bank-side supervision of payment stablecoin activity |
| FDIC | One | Insured-institution treatment of stablecoin issuance |
| NCUA | One (path) | Opened a path for credit unions to participate |
Look at what sits inside the Treasury column, because that is where the limbo bites. Two of its four proposals — the criteria for when a state regime is treated as equivalent to the federal framework, and the registration route for foreign issuers — are the provisions that decide whether a non-US stablecoin business can serve American users and under what conditions. Both are still drafts. For any issuer whose model depends on cross-border reach, the single most important question the Act was supposed to answer is, a year later, unanswered.
GENIUS versus MiCA: law-to-operable
The useful comparison is not GENIUS against some ideal — it is GENIUS against a framework that actually crossed the finish line. Europe’s MiCA regime did exactly what the US has not: it went from law to a hard, enforced deadline. Its transitional period closed on 1 July 2026 with no extension, and after that date serving EU clients without authorisation is a breach of law with real penalties. Whatever one thinks of MiCA’s cost and friction, an operator knows precisely what is required and by when. Our MiCA transition explainer sets out how sharp that line turned out to be.
That is the contrast that should shape decisions. A US issuer today has a law but no operable standard; an EU-facing issuer has a standard and no ambiguity about the deadline. Uncertainty is not neutral — it is a cost. It keeps capital on the sidelines, it makes banking partners cautious, and it stalls product roadmaps that need a fixed compliance target. And it is happening in the largest market precisely as other regimes move ahead: MiCA in Europe, and the Gulf frameworks such as Dubai’s VARA, all of which have rules you can build to now. Weigh those against each other in our best crypto licences guide before you commit a structure.
What this means for you
If you issue or rely on stablecoins, the practical guidance is short and it does not depend on when Washington finishes. Do not wait on US finality. The 120-day clock has not started, the January 2027 backstop is provisional in practice, and the two provisions you most need — foreign-issuer registration and state/federal equivalence — are the least settled parts of the whole file. Planning around a proposal is planning around a draft.
The stablecoin file is also not the slowest-moving one in Washington, which is worth knowing before you assume the rest of the US framework will arrive to rescue it. The market-structure legislation that would define who licenses exchanges, custodians and brokers — the piece the industry actually needs — failed to reach a floor vote before the August 2026 recess. If you were sequencing a US entry on the assumption that stablecoin finality and market-structure law would land together, that assumption no longer holds.
The disciplined move is to anchor your licensing and your banking in a regime that already has operable rules, and let the US framework be something you layer in once it firms up rather than something you build on now. If a stablecoin licence is core to your model, look at jurisdictions with live regimes — our Hong Kong stablecoin licence guide covers one of the clearest. For operators using stablecoins as a settlement rail rather than issuing them, the framework you settle under matters less than the rails themselves working; our stablecoin settlement in iGaming breakdown walks through how that plumbing holds up when the top-level rules are still provisional.
And treat the banking side as the hard part, because it is. Fiat on- and off-ramps are where a stablecoin business actually lives or dies, and they get more cautious, not less, while your regulatory status is uncertain. Line up an EMI or crypto-friendly neobank and settlement partner as part of the plan, never as an afterthought once the licence lands — our crypto-friendly banking guide sets out what genuinely works for high-risk verticals. None of this is investment advice; it is licensing and structuring discipline for a market whose top-tier rules are, for now, still in draft.
The GENIUS Act didn’t fail — it just isn’t finished, and “not finished” is its own kind of risk. If you’re issuing or settling in stablecoins and need a structure that works today rather than one that waits on a clock that hasn’t started, book a free consultation and we’ll map the fastest lawful route, with government and service costs shown separately.
Frequently asked questions
Is the GENIUS Act in force?
The law itself is on the books — President Trump signed the GENIUS Act, the first comprehensive US federal framework for payment stablecoins, on 18 July 2025. But being signed is not the same as being operable. The Act only takes effect on the earlier of 18 months after enactment or 120 days after the primary federal regulators issue final rules, and neither trigger has fired yet.
Why are there still no final stablecoin rules?
One year on, US federal agencies had issued a series of proposed rules and finalised none of them. Treasury put out four proposals, the OCC two, the FDIC one, and the NCUA opened a path for credit unions. Proposals are consultations, not law — until they are finalised, the framework's key operational details remain drafts.
When does the GENIUS Act take effect?
On the earlier of two dates: 18 months after enactment (which lands in January 2027), or 120 days after the primary federal regulators issue final rules. Because no final rules exist yet, the 120-day clock has not started. Unless finals arrive first, the January 2027 backstop is what governs the effective date.
What should a stablecoin issuer do while the rules are pending?
Do not wait on US finality. The operational details that matter — foreign-issuer registration and the equivalence between state and federal regimes — are still in proposal form, so you cannot build to a fixed standard. Anchor your licensing and banking in a regime that already has operable, enforced rules, and treat the US framework as a provision to layer in once it firms up.
Sources
This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.
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