No final federal GENIUS Act rule had appeared in the Federal Register by 27 Sep 2026. Between 19 Sep 2025 and 24 Sep 2026, Treasury (including FinCEN and OFAC), the OCC, the FDIC, the NCUA and the Federal Reserve Board released 13 proposed rules and one advance notice to implement the Act. Treasury expects the Act to take effect on 18 Jan 2027.
The GENIUS Act in brief
The GENIUS Act, Public Law 119-27, was approved on 18 Jul 2025. Once it takes effect, only a permitted payment stablecoin issuer may issue a payment stablecoin in the United States, subject to certain exceptions and safe harbors. Section 2(22) defines payment stablecoins, excluding national currencies, deposits and securities.
Permitted issuers must be formed in the United States and come in three kinds:
- subsidiaries of insured depository institutions approved under section 5 (the Act's term includes insured credit unions);
- federal qualified issuers approved by the OCC: nonbank entities, uninsured national banks and federal branches;
- state qualified issuers approved by a state regulator.
The Act leaves details such as capital, liquidity and operational risk management to regulations. It gave the primary federal regulators, Treasury and the state regulators one year from enactment to issue them.
When the GENIUS Act takes effect
Section 20 of the Act says it "shall take effect on the earlier of (1) the date that is 18 months after the date of enactment of this Act; or (2) the date that is 120 days after the date on which the primary Federal payment stablecoin regulators issue any final regulations implementing this Act."
The primary federal payment stablecoin regulators are the OCC, the FDIC, the Federal Reserve Board and the NCUA. Eighteen months after enactment is 18 Jan 2027. Treasury's proposal of 18 Aug 2026 says the effective date "is expected to be January 18, 2027".
None of the four had published a final implementing rule in the Federal Register by 27 Sep 2026. For the Act to take effect before 18 Jan 2027, a final rule would have had to be issued before 20 Sep 2026, because 120 days after 20 Sep 2026 is 18 Jan 2027.
Every federal GENIUS Act proposal so far
The list covers each proposed rule or advance notice in the Federal Register whose summary ties it to the Act (search of 27 Sep 2026), plus the Fed's two proposals of 24 Sep 2026. All are proposed rules except Treasury's advance notice. The first date in each item is its Federal Register publication date, unless marked "released".
OCC
- Main proposal (2 Mar 2026; comments closed 1 May 2026). Proposed. Activities, reserve assets, redemption, risk management, audits and reports, custody, applications, registration of foreign issuers, and capital with an operational backstop.
- AML and sanctions (24 Jun 2026; closed 24 Jul 2026). Proposed. Bank Secrecy Act and sanctions standards for issuers under the OCC, written in coordination with FinCEN and OFAC.
FDIC
- Applications (19 Dec 2025; closed 18 May 2026, after an extension from 17 Feb 2026). Proposed. How insured state nonmember banks and state savings associations would apply to issue through a subsidiary.
- Requirements and standards (10 Apr 2026; closed 9 Jun 2026). Proposed. Certain requirements for FDIC-supervised issuers and insured depository institutions, deposit insurance for deposits held as reserves, and tokenised deposits.
- BSA and sanctions (5 Jun 2026; closed 4 Aug 2026). Proposed. Compliance standards for FDIC-supervised issuers.
Federal Reserve Board
- Implementing proposal (released 24 Sep 2026). Proposed. Reserves, capital and risk management for Board-supervised issuers; custody rules for Board-supervised firms that safekeep the assets backing payment stablecoins; which stablecoin activities Board-supervised banks may conduct; and a ban on tying that would apply to all permitted issuers.
- Applications (released 24 Sep 2026). Proposed. An application process for Board-supervised banks, with appeals and hearings.
- The Federal Register published both proposals on 29 Sep 2026, and comments must be received on or before 30 Nov 2026. Anvesan's story on the Fed proposals has the detail.
NCUA
- Licensing and investments (12 Feb 2026; closed 13 Apr 2026). Proposed. Licensing of issuers that are subsidiaries of federally insured credit unions; those credit unions could invest only in NCUA-licensed issuers.
- Supplemental proposal (18 May 2026; closed 17 Jul 2026). Proposed. Issuance and related activities, share insurance coverage and tokenised shares.
Treasury
- Advance notice (19 Sep 2025; closed 4 Nov 2025, after a 15-day extension). Questions on regulatory clarity, bans on certain issuance and marketing, AML and sanctions, state and federal oversight, comparable foreign regimes and tax, among other topics.
- State regime principles (3 Apr 2026; closed 2 Jun 2026). Proposed. Principles for judging whether a state regime is substantially similar to the federal framework, under section 4(c).
- Issuance, offer and sale (18 Aug 2026; comments close 19 Oct 2026). Proposed. It would implement section 3: define terms such as "issue" and "located in the United States", give examples of offers and sales, and set exemptions and safe harbors.
FinCEN, OFAC and joint proposals
- AML and sanctions programs (10 Apr 2026; closed 9 Jun 2026). Proposed by FinCEN and OFAC. Permitted issuers would be financial institutions under the Bank Secrecy Act, with AML obligations and sanctions compliance programs.
- Customer identification (22 Jun 2026; closed 21 Aug 2026). Proposed jointly by FinCEN, the OCC, the Fed, the FDIC and the NCUA. Issuers would need an effective customer identification program.
Outside the list, the OCC's proposal of 5 Aug 2026 on disclosing OCC information would also reach issuers it oversees; comments close 5 Oct 2026.
Who is affected
Each federal agency's proposed issuer rules would apply to the issuers under its authority:
- OCC: subsidiaries of national banks and federal savings associations, federal qualified issuers, foreign issuers, and state qualified issuers under its authority.
- FDIC: subsidiaries of insured state nonmember banks and state savings associations.
- Federal Reserve Board: subsidiaries of insured state member banks and, on the Board's reading of the Act, state qualified issuers that are uninsured state-chartered depository institutions and have moved to its framework.
- NCUA: subsidiaries of federally insured credit unions.
State qualified issuers are approved by a state regulator, though the OCC and Fed proposals also cover some of them. Some proposals are not tied to one supervisor: the FinCEN, OFAC and joint proposals, Treasury's section 3 proposal and the Fed's tying ban.
A state qualified issuer with no more than $10 billion outstanding may opt for a substantially similar state regime; Treasury's April proposal would set the principles for that test. Above $10 billion, it must move to the federal framework within 360 days of crossing the threshold, or stop issuing new stablecoins until back under it, unless the applicable federal regulator grants a waiver.
Treasury's August proposal would set how the offer and sale bans apply to exchanges and other digital asset service providers. Under section 18, the section 3 prohibitions do not apply to a foreign issuer that meets conditions including a Treasury finding that its home regime is comparable and registration with the OCC. The OCC, FDIC and Fed proposals would also set custody rules for firms they supervise.
Sherpa lists the US licence as approval as a permitted payment stablecoin issuer, from the Comptroller of the Currency, a federal banking agency or a state payment stablecoin regulator. In the Act, the 120 days is section 5(d)'s deadline for a primary federal regulator to decide, counted from receipt of a substantially complete application. Sherpa's Pathfinder has the full US path.
What to watch next
- 19 Oct 2026: comments close on Treasury's issuance, offer and sale proposal.
- 30 Nov 2026: comments close on the Federal Reserve Board's two proposals.
- Final rules: the Act's one-year deadline, which the NCUA dates to 18 Jul 2026, has passed. The FDIC asked how far final rules should align; the Fed invited comment on differences between its implementing proposal and the other three agencies' approaches.
- 18 Jan 2027: the expected effective date. For up to 12 months from it, the four regulators may waive the Act's requirements for subsidiaries of insured depository institutions and federal qualified issuers with applications then pending. State regulators have a year from it to certify that their regimes meet the substantial similarity criteria.
- 18 Jul 2028: digital asset service providers may no longer offer or sell payment stablecoins not issued by a permitted issuer to people in the United States, subject to the Act's exceptions, such as safe harbors Treasury may set by regulation and the exception for qualifying foreign issuers.
See also Anvesan's United States regime page and the regimes index.