The GENIUS Act is expected to take effect on January 18, 2027; stablecoin companies need to assess their business compliance paths

Odaily reports: The GENIUS Act took effect on July 18, 2025, with the general applicability date being 18 months after enactment, or 120 days after the primary federal payment stablecoin regulator issues final implementing rules, whichever is earlier. The U.S. Treasury Department expects the general effective date to be January 18, 2027, with certain issuance and sales restrictions taking effect on July 18, 2028.

The Office of the Comptroller of the Currency (OCC) published its primary implementation proposal in February 2026, and the Federal Reserve proposed rules on September 24, 2026 covering regulated issuers, reserves, capital, risk management, custody, and application procedures. An interim final rule effective September 30, 2026 has established the forms and procedures for certification of state regulatory regimes.

Stablecoin issuers need to assess approval, prudential supervision, reserve, and redemption requirements; distributors and intermediaries need to analyze exchange, transfer, custody, and related financial services obligations. Companies holding stablecoins also need to review redemption channels, reserve arrangements, custody, freezing, and counterparty risks, and those accepting stablecoin payments need to distinguish between receiving payments for their own goods or services and transferring funds on behalf of others.

Prospective issuers may choose the path of an approved subsidiary of an insured depository institution, a federal qualified issuer, or a state qualified issuer; state qualified issuers that meet the conditions and have outstanding issuance of no more than $10 billion may opt for state supervision. Payment stablecoin reserves must cover outstanding tokens at least one-to-one, and companies also need to map out fund flows, customer rights, compliance responsibilities, and product yield arrangements. Relevant issuers may not pay interest or yield solely by virtue of holding, using, or retaining payment stablecoins. (Bitcoin.com News)