U.S. Payment Stablecoin Legal Implementation Record

U.S. Payment Stablecoin Legal Implementation Record

Enacted law

The GENIUS Act became Public Law 119-27 on July 18, 2025. The enacted text establishes a federal and state framework for permitted payment stablecoin issuers, reserve and redemption requirements, disclosure, supervision, Bank Secrecy Act treatment, and other rules.

Section 20 states that the Act takes effect on the earlier of January 18, 2027, which is 18 months after enactment, or 120 days after the primary federal payment stablecoin regulators issue any final implementing regulations.

Section 3 contains a separate three-year date for the prohibition on U.S. digital asset service providers offering or selling a payment stablecoin unless it is issued by a permitted issuer, subject to statutory exceptions.

Implementation state on July 28, 2026

The reviewed official sources show multiple proposed rules rather than one complete final framework.

The OCC proposed its issuer framework in March 2026. The FDIC proposed requirements and standards for FDIC-supervised issuers in April 2026. Treasury, FinCEN, and OFAC proposed anti-money-laundering, countering-financing-of-terrorism, and sanctions requirements in April 2026. An interagency customer-identification-program proposal was published in June 2026 with comments due August 21, 2026.

The statutory one-year rulemaking deadline passed on July 18, 2026. Missing that deadline does not convert proposals into final rules or make every obligation operational.

Tracker language

Every entry must identify authority, publication date, action type, docket or citation, affected entities, comment or effective date, current status, and next controlling source.

Proposed rules are not final obligations. Final rules can have delayed effective or compliance dates. Statutory enactment, Act-wide effective date, section-specific dates, applications, approvals, state certifications, guidance, and enforcement must remain separate.

Legal boundary

This record is an editorial map, not legal advice. Counsel must determine which federal, state, foreign, licensing, money-transmission, consumer, sanctions, tax, custody, accounting, securities, commodities, banking, and contract requirements apply to a specific entity or product.