The GENIUS Act, signed into law as Public Law 119-27 on July 18, 2025, created the first federal regulatory framework for payment stablecoins — but a new Congressional Research Service report finds the framework had not yet been implemented when the report was written. The gap between enactment and enforcement now defines the policy agenda for issuers, state regulators and federal agencies.

The statute's core prudential rule is a one-to-one reserve requirement: issuers must hold reserves in permitted or regulator-approved assets. Congress simultaneously stated that stablecoins are not backed or guaranteed by the federal government and are not eligible for federal deposit insurance. Lawmakers therefore imposed bank-style reserve and disclosure obligations without creating a prefunded federal mechanism to stop a stablecoin run.

Who can issue a payment stablecoin?

The law regulates issuers rather than tokens or trading venues. An entity may issue a payment stablecoin if a federal regulator or a certified state regulator approves and supervises it. Three categories qualify: depository institutions, nonbank financial firms and approved commercial firms, each mapped to different regulators.

The federal-state split turns on size. Non-IDI issuers with less than $10 billion in outstanding stablecoins may choose federal or state regulation. A state issuer that exceeds that threshold has 360 days to transition to a jointly administered state-federal framework.

The Stablecoin Certification Review Committee — chaired by the Treasury Secretary and including the Federal Reserve chair and the FDIC chair — certifies state regimes as substantially similar to the federal regime and approves commercial issuers. States keep supervisory and enforcement authority over their issuers, but their regimes must meet or exceed federal requirements and undergo annual recertification.

What does the timeline look like?

The statute takes effect on the earlier of 18 months after July 18, 2025 — in early 2027 — or 120 days after final rules are issued. That structure gives rulemaking timing direct commercial significance: faster rulemaking accelerates the compliance deadline for every issuer in the market.

The CRS report identifies the next phase plainly. Federal regulators must establish a standard licensing process, and the Treasury Secretary must publish principles for evaluating state frameworks through notice-and-comment procedures. Those two workstreams will determine whether the dual-track system functions or produces conflicting requirements across jurisdictions.

The framework also fits the administration's broader posture. Executive Order 14178, issued January 23, 2025, called for policies supporting responsible growth and use of digital assets, and the stablecoin law is the first major legislative product of that agenda. Congress paired the narrow stablecoin measure with separate market-structure legislation, which remained under consideration when the CRS report was written.

Which questions remain unresolved?

The report flags several ambiguities in the statutory text that rulemakers must settle:

• Whether the $10 billion threshold applies to a single issuer or to all issuers controlled by one company
• Whether the waiver process for federal supervision is initiated by the issuer, the state regulator or the federal regulator
• How to define payment and settlement for determining which tokens qualify as payment stablecoins
• How regulators should treat stablecoins that fall outside the payment-stablecoin classification

These definitional gaps have direct operational consequences. A conglomerate with multiple issuing subsidiaries could face sharply different supervision depending on how the $10 billion threshold is read. And because retail holders typically redeem through digital-asset service providers rather than directly from issuers, the reach of consumer protections depends on how regulators interpret that redemption chain.

For compliance teams, the practical near-term task is jurisdictional: issuers below the threshold must decide whether state certification or federal licensing better fits their balance sheet and growth trajectory, knowing that crossing $10 billion starts a 360-day clock toward joint supervision. The Treasury's notice-and-comment principles for state frameworks will be the first concrete signal of how strict the certification bar will be — and firms building state-chartered issuance plans will need to model both outcomes before committing.