The federal agencies charged with implementing the GENIUS Act have missed the statute's July 18, 2026 deadline for final rules, leaving US stablecoin issuers preparing against a fixed January 18, 2027 effective date without the final regulations they will be licensed under.

The Office of the Comptroller of the Currency, the FDIC, the Treasury Department, FinCEN, OFAC, and the NCUA all remain at the proposal stage more than a year after President Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins Act (Public Law 119-27) on July 18, 2025.

Section 20 of the law set the effective date at the earlier of 18 months after enactment or 120 days after the primary federal regulators issue final rules. Because the deadline has slipped, the 18-month trigger governs.

What does the missed deadline change?

Treasury's April 3, 2026 proposed rule on certifying state regimes as "substantially similar" closed its comment period on June 2, 2026 without producing a final version. The OCC's supplemental AML proposal (OCC Bulletin 2026-3) opened its comment window on June 22, 2026 — six days after the deadline rules were due — and closes on July 24, 2026.

Dechert's analysis of the OCC's February 25, 2026 notice of proposed rulemaking counts more than 200 specific questions for commenters across new 12 CFR Part 15 and amendments to four other parts. The OCC's announcement framed the package as the first full federal implementing framework under the Act. Several industry lawyers have called the resulting position "the worst of both worlds" — a fixed deadline with unfixed requirements.

Who can issue, and under which pathway?

The Act creates three domestic routes plus a foreign-issuer registration lane:

• Insured depository subsidiary. Banks and credit unions issuing through a dedicated subsidiary under their parent federal banking regulator. No issuance cap.
• Federal qualified nonbank issuer. Fintechs and crypto companies without a bank charter, supervised by the OCC. No issuance cap.
• State qualified issuer. Smaller issuers under a state regime Treasury certifies as substantially similar, capped at $10 billion in outstanding stablecoins. Crossing the ceiling forces a transition to federal supervision or a halt to growth.
• Foreign issuer registration. Offshore issuers such as Tether register with the OCC, contingent on a Treasury comparability determination for the home jurisdiction. None has been issued for El Salvador as of mid-2026.

Circle's June 2025 application for an OCC national trust bank charter slots USDC into the federal nonbank pathway. USDC reserves already sit in short Treasuries and cash at regulated institutions, reported monthly. Per CoinMarketCap data from July 2026, USDC circulation stands at roughly $73.4 billion; USDT sits at about $184 billion globally. Tether has pursued foreign-issuer registration for USDT while launching USAT, a US-compliant coin issued through Anchorage Digital, as a hedge.

What must back each token?

Section 4 requires 1:1 reserves drawn from a tightly enumerated asset list:

• US coins and currency, including Federal Reserve notes
• Demand deposits at insured banks and credit unions
• US Treasury bills with remaining maturity of 93 days or less
• Overnight repurchase agreements collateralized by Treasuries
• Government money market funds invested in the above
• Central bank reserve balances
• Tokenized versions of any of these assets

Corporate bonds, commercial paper, crypto collateral, and algorithmic backing are excluded. Issuers must publish monthly reserve composition reports examined by a registered public accounting firm, with personal CEO and CFO certifications borrowed from Sarbanes-Oxley. Issuers above $50 billion in outstanding coins face annual audited financials, publicly disclosed.

What changes for holders?

Holders gain a first-priority claim on required reserves ahead of all other creditors in an issuer failure — a substantial upgrade over the unsecured-creditor position that defined the Celsius and FTX bankruptcies of 2022-2024. Permitted issuers cannot pay yield on the coin itself. The OCC's February 2026 proposal adds an anti-circumvention presumption against indirect yield paid through affiliates and white-label partners, per Gibson Dunn.

Nothing is banned today. USDT, USDC, PYUSD, and the rest trade on US exchanges. From January 18, 2027, issuing a payment stablecoin to US persons requires a permit. Three years after enactment — July 18, 2028 — digital asset service providers cannot offer or sell payment stablecoins from non-permitted or unregistered foreign issuers. Forkast flagged that date in September 2026 as the operative cliff for exchange-level enforcement.

The next checkpoint is the OCC's supplemental AML comment window, which closes July 24, 2026. Final rules from at least one agency are now expected before the end of 2026 if issuers are to read the rulebook before the January 2027 effective date arrives.