U.S. Payment Stablecoin Regulation Tracker

U.S. Payment Stablecoin Regulation Tracker

The GENIUS Act is enacted federal law, but enactment is not the same as complete implementation. As of July 28, 2026, the official record includes several proposed federal rules and no complete final framework identified in the reviewed sources. Product teams still need current counsel and entity-specific analysis.

This tracker is a navigation aid. The enacted text, final regulations, licenses, orders, and controlling authorities govern.

flowchart LR
    A["Public Law 119-27<br/>July 18, 2025"] --> B["Agency rulemaking"]
    B --> C["Proposed rules"]
    C --> D["Comments and revisions"]
    D --> E["Final rules"]
    E --> F["Effective and compliance dates"]
    F --> G["Applications and issuer approvals"]
    G --> H["Supervision, guidance, and enforcement"]
    I["State regimes and certifications"] --> G

Current status

The GENIUS Act became Public Law 119-27 on July 18, 2025. It establishes a federal and state framework for permitted payment stablecoin issuers and addresses reserves, redemption, disclosures, supervision, Bank Secrecy Act treatment, foreign issuers, insolvency, interoperability, and other matters.

Section 20 says the Act and its amendments take 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.

That Act-wide date does not replace section-specific dates. Section 3 includes a separate three-year point for a prohibition on U.S. digital asset service providers offering or selling payment stablecoins unless issued by permitted issuers, subject to statutory exceptions.

The law also directed regulators to promulgate implementing regulations within one year after enactment. July 18, 2026 passed while several reviewed rules remained proposed. A missed deadline does not turn a proposal into a final rule.

Status vocabulary

These states should never be collapsed into “regulated” or “approved.”

Dated federal implementation record

The table does not claim to be an exhaustive inventory of state action, every agency docket, or later action after the verification date.

The OCC issuer proposal

The OCC's 2026 proposed-issuance page lists its GENIUS Act issuer proposal and later AML, sanctions, customer-identification, and reporting work.

A proposal shows how the agency may implement its jurisdiction. It does not grant an issuer authority, establish a final compliance rule, or resolve how another regulator will treat a different entity.

Any public record should preserve the docket, publication date, comment deadline, current state, and later final action.

The FDIC prudential proposal

The FDIC approved a proposal to implement requirements and standards for issuers under its supervision in April 2026.

The proposal addresses areas such as reserves, redemption, risk management, capital, and other prudential requirements. It applies within the FDIC's supervisory role. It is not one universal rule for every issuer.

The FDIC had separately proposed application procedures in December 2025. Application procedure, prudential standard, approval, and ongoing supervision are different records.

Treasury, FinCEN, OFAC, and customer identification

Treasury announced an April 2026 proposed rule for anti-money-laundering and sanctions compliance programs for permitted payment stablecoin issuers.

In June 2026, FinCEN and the federal banking and credit-union agencies issued a joint customer-identification-program proposal. The Federal Reserve proposal record states that comments were due August 21, 2026.

These are related but distinct. An AML and sanctions program, a customer identification program, transaction monitoring, secondary-market activity, and obligations of merchants or service providers should not be treated as one rule.

State and federal interaction

The Act creates roles for federal and state qualified issuers and a process for evaluating state regimes. The controlling route can depend on entity type, charter, scale, state regime, and regulator.

State licensing, money transmission, consumer, custody, commercial, tax, and other requirements may continue to matter even when federal stablecoin provisions apply.

The tracker should add state certifications and approvals only from the controlling state or federal record. A company's statement that it is compliant or ready is not a regulator decision.

Issuer status and product status are separate

An issuer approval does not automatically approve every wallet, exchange, merchant, processor, card, or customer use.

A product can support a stablecoin before the GENIUS Act's full effective date under another legal framework. It can also need changes when final rules and compliance dates arrive.

The Stripe stablecoin-payment documentation can establish Stripe's current product scope. It cannot establish that a stablecoin issuer, merchant, or customer satisfies every applicable law.

How to maintain this page

Each update should record the authority, date, action type, citation or docket, affected entities, statutory basis, comment deadline, effective date, compliance date, current state, and next controlling source.

Proposed and final rules should receive separate entries. Corrections, extensions, court challenges, regulator designations, approvals, denials, guidance, and enforcement should not overwrite the earlier history.

A named legal owner should perform a same-day source check before publication and maintain a rapid correction or unpublish process.

[[How to Evaluate a Stablecoin Payment Workflow]] uses this tracker only as a starting point. Counsel must determine the law for the actual entity, customer, asset, chain, product, and corridor.

Editorial note

This living legal reference was developed with AI assistance from E043 and the linked enacted law, Congress, Treasury, OCC, FDIC, Federal Reserve, FinCEN, OFAC, NCUA, and product sources. Dalton Anderson remains the author. Continuous legal, regulatory, state, source, effective-date, and founder review are mandatory. This page is not legal, financial, tax, accounting, sanctions, custody, or investment advice. Publication is not authorized.