The GENIUS Act cleared Congress a year ago, but the U.S. stablecoin rulebook is still unfinished

The first anniversary of the GENIUS Act was supposed to mark the end of the opening phase of U.S. stablecoin rulemaking. Instead, it arrived with the federal framework still in draft form. The law set a one-year timetable for much of the implementation work, and the date passed without a final package from the Treasury Department, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Federal Reserve or the National Credit Union Administration. For issuers, banks and infrastructure providers, that leaves the market in an awkward middle ground: Washington has chosen a regulatory direction, but some of the operating rules that will define how that direction works in practice are not yet locked in.

That gap matters because the GENIUS Act was designed to move stablecoins out of the gray zone and into a formal supervisory perimeter. The statute established a national framework for permitted payment stablecoins, including reserve, licensing, risk-management and anti-money-laundering expectations. It also created a pathway for multiple federal regulators to oversee different types of issuers while Treasury evaluates whether state-level regimes are substantially similar to the federal standard. In other words, the law was never just a headline political win for the sector. It was meant to become an operating manual for a market that now sits close to the center of dollar settlement, exchange liquidity, onchain payments and tokenized-asset collateral flows.

Public rulemaking records show that agencies have been active, but not finished. The OCC published a proposed rule on March 2 covering payment stablecoin issuance by entities under its jurisdiction. The FDIC followed on April 10 with a proposal covering requirements and standards for FDIC-supervised stablecoin issuers and insured depository institutions. On the same day, FinCEN and OFAC published a joint proposed rule on anti-money-laundering and sanctions compliance for permitted payment stablecoin issuers. The NCUA published its own proposal on May 18 for credit-union-linked issuance, and FinCEN returned on June 22 with a joint customer-identification-program proposal involving the OCC, Federal Reserve, FDIC and NCUA. The Federal Reserve also opened a July 9 proposal tied to anti-money-laundering and counter-terrorist-financing program obligations.

Those publication dates help explain why the deadline passed before the final rulebook was ready. Some comment windows only closed recently, and others are still open. The OCC proposal took comments through May 1, the FDIC and FinCEN/OFAC proposals through June 9, and the NCUA proposal through July 17. More important, the joint customer-identification proposal remains open until Aug. 21, and the Federal Reserve’s July proposal remains open until Sept. 8, according to Federal Register records. That means the agencies are still in the part of the Administrative Procedure Act process where they must gather and evaluate feedback before finalizing the text. The market has direction, but not a settled compliance baseline.

The remaining uncertainty is not abstract. Final rules will determine how reserve standards are calibrated, how bank and nonbank issuers document compliance, how supervisors coordinate across charters, what reporting regimes become routine and how anti-money-laundering controls are operationalized for stablecoin businesses that increasingly intersect with traditional payments rails. Treasury’s own implementation work also matters because state-regulated issuers and foreign stablecoin access depend on how the federal government draws the boundaries of equivalence, registration and ongoing oversight. Until that work is completed, legal teams can plan against a policy trajectory, but they cannot treat every supervisory detail as settled.

For the market, the immediate effect is likely to be uneven rather than dramatic. Large issuers and distribution partners already have strong incentives to behave as if stricter supervision is coming, especially in products tied to exchange liquidity and institutional payments. Names such as USDC, USDT and PYUSD are already central to trading, treasury management and settlement activity across crypto venues and onchain finance. But a delay in final rulemaking can still shape competition. It favors firms with the balance sheet, licensing footprint and compliance budget to absorb ambiguity, while raising the execution burden for smaller entrants that need a fixed rule set before expanding products, banking relationships or U.S. distribution plans.

None of this suggests the framework has stalled. The public record points to an implementation process that is still moving, just not on the original statutory calendar. That distinction matters. Missing a deadline does not erase the law or unwind the proposals already on the table, but it does postpone the moment when the U.S. stablecoin market can point to a completed federal operating standard. The next signal to watch is not another political declaration about stablecoins. It is the sequence of final rules that turns a landmark statute into an enforceable playbook for issuers, banks and the tokenized-dollar infrastructure growing around them.