GENIUS Act deadline puts stablecoin issuers on the clock
The GENIUS Act sets a one-year deadline, until July 18, 2026, for regulators to write implementing rules for stablecoin issuers. That deadline is not a full cutoff; the Act’s effective date is earlier of 18 months after enactment or 120 days after final rules. The main issue is who can qualify as a permitted payment stablecoin issuer, since others are generally barred from issuing payment stablecoins in the US. Rulemaking is expected to be broad, covering eligibility, registration, supervision, reserves, redemption, custody, revocation, and capital backstops. Compliance requirements will likely be heavy: permitted issuers would face Bank Secrecy Act, AML, sanctions, and lawful-order obligations, with additional OCC supervision for certain issuers. Foreign issuers must meet separate reciprocal-arrangement and lawful-order conditions, while state-qualified issuers depend on Treasury deciding whether state regimes are substantially similar to the federal framework. The biggest pressure points are new federal applicants, foreign issuers, and state issuers waiting on equivalence decisions.
