Seven proposals, no final rules, and a statute that takes effect on January 18 regardless. This page tracks each rulemaking and what it changes for the companies that move dollars on chain.
The law’s timing clause is the thing to understand first. The GENIUS Act takes effect on the earlier of January 18, 2027, or 120 days after the primary federal regulators issue final implementing rules. Regulators missed the statutory rulemaking deadline of July 18 this year. Nothing about that delay moves the effective date.
So the industry is four months from a live statute with a rulebook made entirely of proposals. Comptroller Jonathan Gould told an audience in August that the OCC intends to get a final rule out by November so it can start processing applications in the new year. That leaves roughly eight weeks between a final rule and the day the law binds.
What follows is the state of each proceeding as of mid-September, in the order the pieces fit together. This page gets updated as rules land, and each new rule will get its own dated news item pointing back here.
What binds on day one, rules or no rules
A useful way to read the proposals is to separate what the statute already says from what the agencies are still filling in.
On the effective date it becomes unlawful for anyone other than a permitted issuer to issue a payment stablecoin in the United States. Issuers must hold identifiable reserves backing outstanding tokens at least one to one, publish the monthly composition of those reserves on their website, have the previous month’s report examined by a registered public accounting firm, and file a monthly certification of accuracy signed by the chief executive and chief financial officer. They must maintain clear procedures for timely redemption, with any fees stated in plain language.
None of that waits for a final rule. The rulemakings decide how those duties are supervised, what an application looks like, which reserve assets qualify in detail and who examines whom. The duties themselves arrive on schedule, which is why counsel at the larger issuers have spent this year building to the statute and treating the proposals as commentary.
The OCC proposal: the main rulebook
The OCC opened the substantive rulemaking with a notice announced in the OCC’s proposal on February 25 and published in the Federal Register on March 2. Comments closed on May 1.
It is the broadest of the set. The proposal covers permitted activities and reserve assets, redemption and risk management standards, audits, reports and supervision, custody, the application and registration process for becoming a permitted issuer, capital adequacy, prompt corrective action and assessments. It applies to national banks, federal savings associations, federal branches, certain nonbank entities seeking federal qualification, and foreign issuers meeting the statutory criteria.
For anyone running a card program or a wallet, two parts matter beyond the licensing machinery. The application process determines which issuers will exist in the United States next year, which determines which tokens a program can safely hold. And the proposal’s treatment of interest and yield extends to arrangements with affiliates and related third parties, which is a separate subject with its own commercial consequences.
Read more: Tether posts a record quarter while its freeze powers go to court • OCC trust charters give stablecoin issuers a federal front door
The FDIC proposal: reserves and the insurance question
The FDIC published its proposed standards on April 10, with comments closing June 9.
The reserve rules are the expected ones. Issuers it supervises would hold reserves one to one against outstanding tokens, in a permitted list that includes United States currency, Treasury bills of 93 days or less, deposits at banks and money market funds. Reserves cannot be pledged. Issuers cannot pay interest solely for holding a token, and cannot extend credit to customers.
The sentence that deserves the most attention is about insurance. Deposits held as reserves backing a stablecoin would be insured to the issuer under the rules for corporate deposits, and would not be insured to the token holders on a pass-through basis. Any marketing that implies a stablecoin balance carries deposit insurance is describing something the proposal says does not exist.
The proposal also states that tokenized deposits are not payment stablecoins, which matters for the banks building deposit tokens instead of issuing coins.
The NCUA track: smaller but real
The NCUA proposed its application framework in February, published standards for credit union issuers in the Federal Register on May 18, and followed in July with a supplemental proposal covering issuance by credit union subsidiaries.
The volumes here will be small next to the bank and nonbank issuers. The track matters because it sets the pattern for how a supervised depository institution, not a fintech, gets into issuance, and credit unions serve exactly the kind of member base that stablecoin payment products are marketed toward.
The AML and identification proposals
Two proceedings run through FinCEN.
On April 8, FinCEN and OFAC issued a joint proposed rule requiring permitted issuers to meet Bank Secrecy Act obligations and to maintain an effective sanctions compliance program. It published on April 10 and comments closed June 9. The proposal would also require issuers to hold the technical ability to identify, block, freeze or reject transactions in the secondary market.
On June 22, FinCEN and the four banking agencies published a customer identification proposal for the same issuers: name, date of birth or date of formation, address and an identification number, with risk-based verification and records held five years past account closure. Comments closed August 21.
Both proposals draw the same line. The customer is whoever mints or redeems directly with the issuer. Someone who acquires tokens on the secondary market and spends them has no identification relationship with the issuer at all, which leaves the identity work with the platforms and card programs downstream.
The state pathway
Treasury published broad-based principles on April 3 for deciding whether a state regulatory regime is substantially similar to the federal framework, with comments closing June 2.
The structure is straightforward. An issuer that is not affiliated with an insured depository institution and has less than $10 billion outstanding can choose state supervision, provided the state regime is certified. Certification runs through the Stablecoin Certification Review Committee, chaired by the Treasury Secretary, with the Federal Reserve and the FDIC alongside. Cross $10 billion and the issuer transitions to federal regulation or requests a waiver to stay where it is.
For everyone downstream, the practical question is which states get certified and when. A card program relying on a state-qualified issuer is relying on a certification that has not happened yet.
The perimeter proposal: who can offer what to whom
The most recent proposal is also the one with the longest reach. Treasury published rules on issuance, offer and sale on August 18, implementing section 3 of the Act. Comments close on October 19.
Two dates sit inside it. Restrictions on what digital asset service providers may offer take effect on July 18, 2028, at which point a platform cannot offer a payment stablecoin to United States persons unless a permitted issuer issued it. The rules for foreign issuers under section 18(a) apply from the Act’s effective date, and would let a platform offer a foreign-issued token only where the issuer can comply with lawful orders and the home jurisdiction has a reciprocal arrangement.
This is the proposal that reaches wallets, exchanges and card programs directly, because it governs what can be listed, held and offered, not what can be minted. The consequences for the largest offshore issuer are their own story, covered in our piece on Tether’s American surface.
What is still missing
Three gaps are worth naming.
There is no final rule anywhere in the set. Every item above is a proposal, and until one is finalized, the 120-day clock in the statute never starts, which is why January 18 remains the operative date.
There is no standalone Federal Reserve licensing proposal in the public record, although the Fed joined the customer identification proposal and sits on the certification committee. Firms expecting a Fed-supervised route to issuance are waiting on something that has not been proposed.
And the reporting machinery has arrived ahead of the substance. The OCC published reporting forms and instructions for permitted issuers in June, which means the agency has decided what it wants to collect before it has finalized what it requires.
Charters are the one area where the record is already thick, and those are covered separately in our story on OCC trust charters, which are a different approval from the issuer licence this rulemaking creates.
The two dates that split the market
One detail causes more confusion than any other, so it is worth stating plainly.
The prohibition on issuing without a permit bites on the effective date. The restriction on what platforms may offer does not arrive until July 18, 2028. In between sits a period where a token can exist and be traded without its issuer being permitted in the United States, while American platforms are still allowed to offer it under the transition.
That gap is deliberate, and it is where most commercial planning is happening. Issuers have to be ready first. Wallets, exchanges and card programs have a longer runway to change what they list, which is why a program holding a token from an unpermitted issuer in February will not be breaking the law, and why waiting until 2028 to think about it would be a mistake.
What each layer should be doing now
For prospective issuers, the work is application readiness: reserve composition that matches the permitted list, a redemption policy that survives a bad week, audited financials, and a compliance program that exists before the examiner asks.
For card programs and wallets, the work is contractual. Know which issuer stands behind every token the program holds, whether that issuer is on a federal or state track, and what happens to the program if the issuer is not permitted by January. Check any marketing that mentions insurance against what the FDIC proposal actually says.
For exchanges and platforms, the perimeter proposal is the one to read closely, because it decides what can be offered to American users and on what evidence, and the 2028 date is early enough to matter to product roadmaps being written now.
How this page is maintained
Two rules govern this tracker, stated once so readers can hold us to them.
Every entry carries the agency, the document, the date it was issued or published, the comment deadline and the current status, and each status is one of four words: proposed, comments closed, final, or withdrawn. Where an agency issues a supplemental proposal, it is added under the same entry instead of starting a new one, so the sequence stays readable.
When a rule is finalized, the entry is updated and a separate dated news item covers what changed. This page is the reference; the news items are the record of movement. Corrections are marked in place rather than quietly edited.
The calendar from here
Four dates frame the rest of this.
October 19 closes comments on the perimeter proposal, the last major comment window open. November is the OCC’s stated target for a final rule, which would start the 120-day clock and would still land after January 18. January 18 is the statutory effective date, when the law binds whether or not the rules are finished. And July 18, 2028 is when platforms must stop offering payment stablecoins from issuers that are not permitted.
The pattern across all of it is a regime that arrives in the wrong order: obligations first, rules second, applications third. Firms that wait for certainty will be applying to a regulator already working through a queue. This page will mark each rule as it lands, and the entries above will be updated rather than rewritten, so the history of what changed stays readable.