Stablecoin issuers face uncertainty after federal regulators missed the GENIUS Act's one-year rulemaking deadline. BlackRock challenges proposed 20% reserve limit; state issuer certification unresolved. Effective date Jan 2027 still stands.
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Federal regulators missed the GENIUS Act's one-year rulemaking deadline, leaving stablecoin issuers without final compliance rules despite a statutory requirement to have them in place by July 18, 2026.
President Trump signed the GENIUS Act into law on July 18, 2025. The law gave the Treasury Department, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Federal Reserve and the National Credit Union Administration 12 months to finalize regulations. None of the agencies met that deadline, according to public dockets and agency statements.
The agencies have only issued proposed rules. Several comment periods remain open, and some have been extended past the statutory window. That prevents regulators from adopting final rules until the consultation process ends.
The delay does not pause the law itself. The GENIUS Act takes effect on Jan. 18, 2027. Stablecoin issuers must comply by then, even though many operating requirements – covering reserve assets, liquidity, custody, reporting, anti-money laundering, redemption rules and foreign issuer registration – are still in draft form.
BlackRock, the world's largest asset manager, asked the OCC to drop a proposed 20% limit on tokenized reserve assets. In a comment letter, BlackRock also sought assurance that Treasury-issued exchange-traded funds would qualify as eligible reserves. The asset manager has been pushing for wider stablecoin adoption through its own tokenization efforts and partnerships with exchanges and custodians. Visa, BlackRock Stablecoin Push Tops Crypto KOL Sentiment covers the broader industry momentum.
Another unresolved piece involves state-regulated issuers. The GENIUS Act lets issuers with outstanding stablecoins under $10 billion remain under state supervision, provided the state's regulatory framework is “substantially similar” to the federal one. The Treasury Department has not yet finalized the certification process for those states.
With the implementation window narrowing, companies may start preparing based on the proposed regulations. If the final rules differ materially, compliance costs for new stablecoin entrants could rise. Congress could also expand its oversight of the rulemaking process before the January effective date.
The effective date remains Jan. 18, 2027. No agency has indicated when final rules will be published.
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