GENIUS Act: what the stablecoin law requires and when

Short answer

The GENIUS Act takes effect on 18 January 2027, according to the OCC. From then, only permitted payment stablecoin issuers may issue payment stablecoins in the US. Tokens must be backed at least 1 to 1 by cash, Treasuries maturing in 93 days or less and other listed assets. Issuers must publish monthly reserve reports and may not pay interest or yield solely for holding the token.

• What happened The OCC finalised its GENIUS Act rule on 21 October 2026, effective 18 January 2027.
• Why it matters From that date, only a permitted payment stablecoin issuer may issue a payment stablecoin in the US.
• What is still open Other agency rules were last confirmed as proposals, and OCC applications have not opened.
• What to watch Whether other agencies finalise rules before 18 January 2027.

Last checked 2026-10-24

Key facts

Law	Public Law 119-27 (S.1582), approved 18 July 2025
House vote	308-122, the day before signing
Effective date	18 January 2027 (18 months after enactment), per the OCC
Reserve rule	At least 1 to 1, Treasuries limited to 93 days or less
State option	Issuers with up to $10,000,000,000 outstanding may choose a state regime
Service provider deadline	3 years after enactment, service providers may not offer or sell to US persons a payment stablecoin from a non-permitted issuer (exceptions apply)

What happened, and when?

The GENIUS Act became Public Law 119-27 on 18 July 2025. According to The Block, the House passed it 308-122 the day before President Trump signed it.

Signing did not switch the law on. It takes effect on whichever comes first: 18 months after enactment, or 120 days after the primary federal regulators issue final implementing rules. Eighteen months from 18 July 2025 is 18 January 2027, the date the OCC gives for both its rule and the Act. The 120-day route cannot come first. Even counting from the OCC rule's Federal Register publication on 23 October 2026, 120 days runs past 18 January 2027. The law applies whichever date comes first, so 18 January 2027 is the effective date.

Congress told regulators and Treasury to write their rules within one year, by 18 July 2026. That deadline passed with most rules still at proposal stage. The OCC announced its final rule on 21 October 2026, and the Federal Register published it on 23 October 2026.

Date	Agency	Action	Status
25 Feb 2026	OCC	Proposed rule	Proposal
8 Apr 2026	FinCEN and OFAC	AML and sanctions program rule for issuers	Proposal
9 Apr 2026	FDIC	Proposed rule, comments due 9 Jun 2026	Proposal
17 Aug 2026	Treasury	Section 3 rule on issuance, offer and sale	Proposal, 60-day comment period
24 Sep 2026	Federal Reserve Board	Reserve, capital and application rules	Proposal
21 Oct 2026	OCC	Final rule, effective 18 Jan 2027	Final

What does the GENIUS Act require of stablecoin issuers?

The Act is first a licence requirement. It makes it unlawful for anyone other than a permitted payment stablecoin issuer to issue a payment stablecoin in the United States.

Permitted issuers must be formed in the US and fit one of three types. Their obligations focus on what backs each token and how holders get their money back.

• Reserves: identifiable reserves of at least 1 to 1, limited to cash, Federal Reserve balances, insured deposits, Treasuries maturing in 93 days or less, certain repos, government money market funds and similar assets.
• No reuse: reserves may not be pledged, rehypothecated or reused, except for narrow listed purposes.
• Redemption: issuers must publish a redemption policy and disclose all fees. Fees can change only with at least 7 days' notice to consumers.
• Monthly reporting: reserve composition must be published each month and examined by a registered public accounting firm. The CEO and CFO must certify it, with criminal penalties for false certification.
• Larger issuers: those above $50 billion outstanding also face annual audited financial statement requirements.
• No yield from the issuer: issuers may not pay interest or yield solely for holding, using or keeping a payment stablecoin.

Issuer type	Who approves or supervises	Note
Subsidiary of an insured depository institution	Approved under the bank's regulator	The FDIC issued a notice in December 2025 on procedures for state nonmember banks seeking approval for a stablecoin subsidiary
Federal qualified issuer	Includes nonbanks approved by the OCC	OCC has not yet opened applications
State qualified issuer	State regulator	Allowed up to $10,000,000,000 outstanding if the state regime is substantially similar to the federal one

What changes for stablecoin holders?

If an issuer becomes insolvent, holders' claims have priority over other claims on the required reserves. A second provision deals with securities law. The first provision concerns who gets paid in a failure. The second concerns how the token is classified: a payment stablecoin from a permitted issuer is excluded from the definition of security under the Investment Advisers Act and related laws.

None of this means holders will always be paid in full. Priority applies only to the reserves the issuer is required to hold.

Who is affected?

Banks can issue through a subsidiary, nonbanks can apply to the OCC, and issuers with up to $10,000,000,000 outstanding can choose a qualifying state regime.

Exchanges and other digital asset service providers face a later deadline. Three years after enactment, they may not offer or sell a payment stablecoin to US persons unless a permitted issuer issued it, subject to exceptions.

Foreign issuers are affected through Treasury's August 2026 proposal. It defines when a stablecoin is issued, offered or sold in the US, which decides whether an overseas token falls inside the rules.

The interest ban in the Act is written for issuers. This article does not cover whether exchanges or other third parties may offer rewards on stablecoins.

What should readers watch next?

The fixed date is 18 January 2027, when the Act and the OCC rule take effect. After that, the next fixed statutory date in the Act is the service provider deadline, three years after enactment.

• Whether the FDIC, Federal Reserve, Treasury and FinCEN/OFAC finalise their proposals before 18 January 2027.
• A separate rulemaking with Treasury on Bank Secrecy Act, anti-money laundering and OFAC sanctions rules, which the OCC left out of its final rule.
• When the OCC begins accepting issuer applications.
• Whether any state regime is certified as substantially similar to the federal framework.

What is not confirmed yet?

Several details circulating about the rules have not been checked against primary documents.

• Specific terms of the OCC final rule reported by secondary outlets, including liquidity, redemption timing, capital and third-party rewards, have not been checked against the rule text in the Federal Register.
• The Federal Register publication date of Treasury's 17 August 2026 proposal, which starts its 60-day comment period.
• The current status of final rules from the FDIC, Federal Reserve, Treasury and FinCEN/OFAC.
• When OCC applications open, and whether any issuer will be permitted by 18 January 2027.
• Whether the Stablecoin Certification Review Committee has certified any state regime.

Is this article advice, and does the law apply where you live?

Disclaimer: this article is general information only. It is not legal, tax, financial or investment advice, and it describes US law only.

Availability: stablecoins and related services may not be available in your country or region. Local rules can differ from the US framework, so check what applies where you live.

FAQ

Sources

• Public Law 119-27 (GENIUS Act), GovInfo
• OCC News Release 2026-92 (final rule)
• OCC Bulletin 2026-50 (final rule)
• US Treasury press release sb0605
• OFAC recent action 20260408_33 (FinCEN/OFAC proposal)
• Mayer Brown – FDIC proposal
• The Block – Fed proposal
• The Block – signing

Figures change. Check the primary sources below.