U.S. regulators failed to meet a July 18 deadline to complete rulemaking for the GENIUS Act, leaving key regulatory frameworks for stablecoin issuers still pending. A number of important proposals on reserves, redemptions, capital, custody and compliance are still under review at the federal level.
Unless the final regulation triggers an earlier effective date, the law will come into effect on January 18, 2027 at the latest. Because federal compliance requirements have not yet been perfected, issuers, banks and exchanges now face months of uncertainty and need to plan without policy clarity.
The federal stablecoin rulebook is still incomplete
U.S. financial regulators missed the July 18 rulemaking deadline set by the GENIUS Act, making the country's new payment stablecoin framework largely dependent on unfinished proposals. Although the delay does not suspend enforcement of the law, it adds complexity to the preparation of issuers, banks, exchanges and other companies before the January 2027 effective date.
The missed deadline occurred one year after the law was signed into effect. U.S. President Donald Trump signed the GENIUS Act on July 18, 2025, establishing the first comprehensive federal regulatory framework specifically for payments in stablecoins.
Under the law, only entities approved by federal or state regulators can issue qualified tokens, and issuers must maintain reserve assets equal to the value of stablecoins in circulation. The framework aims to make dollar-pegged tokens more like regulated payment instruments than loosely regulated digital products. To do this, approved issuers must hold a 100% reserve consisting of highly liquid assets such as cash, bank deposits and short-term treasury bonds.
The law also establishes standards for redemption, reserve disclosure, capital, liquidity, custody, risk management and bankruptcy protection. In addition, issuers are not allowed to pay interest directly to holders and must comply with anti-money laundering and sanctions compliance requirements under the Bank Secrecy Act.
Despite these statutory requirements, the agencies responsible for implementation have not yet completed their core rulebook. In March this year, the Office of the Comptroller of the Currency issued a broad proposal covering licensing, reserves, redemption, capital, custody and supervision. The Federal Deposit Insurance Corporation subsequently proposed prudential regulatory standards for State Bank's stablecoin subsidiaries. At the same time, the National Credit Cooperative Administration has also introduced separate licensing and operating requirements for credit cooperative subsidiaries.
However, none of these main frameworks was finalized on the first anniversary of the law's entry into force. After the July 18 deadline passed, a number of related proposals were still in the public solicitation stage. For example, the comment period for a joint customer identification proposal will last until August 21; meanwhile, the FDIC's proposal for compliance with the Bank Secrecy Act and sanctions will accept public comment until August 4; in addition, the feedback deadline for the proposed FDIC reporting form is September 18. Regulators will then need to review these comments and coordinate standards among banks, credit unions, non-bank issuers, state regulatory systems, and foreign companies.
As a result, several important areas of compliance remain unresolved. The pending frameworks cover capital levels, reserve valuations, redemption schedules and licensed business activities under different regulatory regimes, and also cover foreign companies that want to reach U.S. customers under the law. Companies must continue to prepare around these unfinished requirements until regulators finalize these standards.
January 2027 becomes a key compliance date
Missing the rule setting date will not immediately lead to the illegality of stablecoins, nor will it lead to automatic violations by existing issuers. Instead, the GENIUS Act will take effect on January 18, 2027, or 120 days after the final regulation is issued, whichever is earlier. Since the complete rule package has not yet been completed, January 18, 2027 has now become the clearest operating date based on the law's existing timetable. Agencies still have months to complete rulemaking and provide companies with clearer compliance guidance.
This period is crucial considering that the stablecoin market has exceeded US$300 billion in April 2026. Issuers may need to restructure reserves, improve customer identification systems, establish redemption procedures, and choose federal or state regulation. Banks and cryptocurrency platforms must also determine which tokens they can support under the new regime. Final rules will define how activities other than custody, foreign stablecoins, incentive programs and issuance are included in the framework.
For now, missed deadlines keep the law itself intact, but operational details remain imperfect. As a result, the industry has entered the final stage of preparation, when the basic principles have been established and key procedures are still pending approval.

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