The U.S. Treasury Department has issued an interim final rule allowing states to file stablecoin-regime certifications with the federal government before their own legislative and regulatory work is complete. The rule, published in the Federal Register on Sept. 30 and effective the same day, sets the forms and review procedures for the Stablecoin Certification Review Committee, the federal body that evaluates whether state stablecoin regimes qualify for approval.

The Committee stated that conditional or incomplete certifications can satisfy the initial filing timeframe even when additional state legislative or regulatory action is still planned. That flexibility carries a procedural boundary: a conditional filing can be amended at any time, but it does not begin substantive review and does not start the Committee's 30-day approval-or-denial clock. That clock runs only once a certification has been submitted in full accordance with the procedures.

A complete submission requires an unconditional attestation signed by an authorized state representative, a detailed explanation of how the state regime meets Treasury's substantial-similarity criteria, supporting legal materials, and any additional information the Committee deems necessary. The interim rule does not finalize those similarity principles, which remain the subject of a separate Treasury proposal on the standards used to compare state and federal regimes.

The stakes are concrete for state-qualified payment stablecoin issuers. Under the GENIUS Act framework, issuers with no more than $10 billion in consolidated outstanding payment stablecoin issuance may opt for state regulation if the state regulator certifies that its regime meets Treasury's substantial-similarity criteria and the Committee unanimously approves it as meeting or exceeding the standards in section 4(a) of the Act. Regime approval, however, does not grant an individual issuer license — states retain the burden of completing their frameworks before substantive review can proceed.

One procedural gate remains before any filings land. The rule states that certifications will not be accepted until the information collection receives approval under the Paperwork Reduction Act. Treasury will post a public notice announcing when acceptance begins, meaning states aiming to use the early-filing flexibility must wait for that signal even though the rule is already in effect.

The timeline is anchored to the GENIUS Act's expected Jan. 18, 2027 effective date, with initial certifications due Jan. 18, 2028 — one year after the statute takes effect. That date could move earlier. Section 20 of the Act sets effectiveness at the earlier of 18 months after enactment or 120 days after primary federal payment stablecoin regulators issue any final implementing regulations, which would compress the filing window for states that move slowly.

For state legislatures and regulators still drafting stablecoin frameworks, the interim rule effectively decouples the filing deadline from the completion deadline. A state can lock in its position in the queue with a conditional certification and finish its legislative work during the amendment period, rather than risk missing the statutory window entirely. The trade-off is legal: until the filing becomes complete and unconditional, no substantive review occurs and no approval clock runs.

Comments on the interim procedures are due Nov. 30, giving states, issuers, and industry groups roughly two months to weigh in before Treasury finalizes the review framework that will govern the first round of state certifications.