The main regulatory agencies of the United States missed the one-year deadline set by the GENIUS Act without finalizing the rules that will implement the new federal framework aimed at stablecoins. The legislation, signed by the current U.S. president, Donald Trump, on July 18, 2025, established a timeline for the rules to be published after public consultation, but part of this work remains pending.
The GENIUS Act was created to define a set of rules for payment stablecoin issuers, including requirements related to reserves, redemptions, transparency, licensing, and supervision. Although these principles are already provided for in the legislation, several operational details still depend on regulation by the competent authorities.
Among the agencies that have not yet finalized their proposals are the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Treasury Department. In addition, proposals involving the Federal Reserve and the authorities responsible for combating money laundering remain under public consultation or are awaiting review.
The OCC presented a broad set of rules addressing the composition of reserves, liquidity, capital, risk management, custody, and reporting obligations for issuers under its supervision. The FDIC, in turn, released a proposal focused on prudential standards, including criteria for reserves, redemptions, and the treatment of deposits related to stablecoins.
In the case of the NCUA, one of the public consultations was closed only one day before the deadline set in the GENIUS Act. In practice, this made it impossible for the agency to analyze the contributions received and publish final regulation within the period established by the legislation.
The Treasury Department also did not finalize the guidelines that will define when a state regime may be considered equivalent to the federal model. This definition is important so that issuers with up to US$ 10 billion in stablecoins in circulation can remain under state supervision, provided they meet the established requirements.
Another ongoing proposal involves joint rules from the Federal Reserve, FinCEN, OCC, FDIC, and NCUA for customer identification procedures in the primary market. The period for submitting comments remains open until August, while other proposals related to anti-money laundering and compliance with economic sanctions also remain under review.
In addition to the delay in publishing the rules, regulators still need to evaluate suggestions submitted by participants in the financial market. Among the topics under debate are the composition of the assets that may serve as reserves and the possibility of using certain Treasury ETFs as part of these guarantees.
The delay also maintains uncertainties for states that intend to adapt their own legislation. New York, for example, presented a framework inspired by the GENIUS Act, including additional rules for reserves and risk management. However, without the final federal rules, states may be required to revise their models before obtaining certification.
Despite the failure to meet the one-year deadline, the GENIUS Act does not provide for automatic penalties for regulatory agencies. The text determines that the legislation will take effect on the earlier of the following dates: January 18, 2027 or 120 days after the publication of the final rules by the main federal regulators. Meanwhile, stablecoin issuers continue preparing their operations based on the proposals currently available, which may still undergo changes before the final version.