One year on, the GENIUS Act is still waiting on its own rulebook

On 18 July 2025, President Donald J. Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins Act into law, formally placing the United States on a legislated path to oversee the dollar-pegged tokens that now move tens of billions of dollars a day across crypto markets. Twelve months later, the rulebook the law required still does not exist.

The Treasury Department, the Federal Reserve, the Office of the Comptroller of the Currency and other federal agencies were given one year to translate the GENIUS Act's framework into binding regulation: who can issue a payment stablecoin, how reserves must be backed, what disclosures are mandatory, and how non-bank issuers gain access to the banking system. On 19 July 2026, Cointelegraph reported that US agencies had instead issued ten proposed rules rather than final ones, missing the statutory deadline by hours or, depending on how one counts the clock, by the better part of a year.

The framework the law set, and the rules that were supposed to follow

The GENIUS Act was the first federal statute to define a "payment stablecoin" as a digital asset redeemable one-for-one for fiat currency, with reserves held in cash, short-dated Treasuries or similarly liquid instruments. It drew a hard line between domestic issuers, who must register and meet capital and disclosure requirements, and offshore issuers, who can serve US customers only if their home regimes are deemed comparable by Treasury. It opened a narrow channel for non-bank issuers to obtain FDIC-insured accounts or master accounts at the Fed, and it gave the OCC a new chartering pathway for stablecoin issuers.

None of those provisions is operational without implementing regulation. The act specifically directed federal banking regulators to finalise rules on reserves, redemption, liquidity, capital, examination and consumer disclosure within 365 days. The OCC was to publish its issuer-charter rule. The Treasury Secretary was to issue the comparability determination framework for foreign jurisdictions. Each of those deadlines lapsed between late 2025 and mid-2026.

What regulators have actually produced

What exists, per the Cointelegraph summary of the 19 July 2026 filings, is ten proposed rulemakings published across multiple agencies. The proposals sketch out how issuers might report reserves, how banks might custody stablecoin collateral, and how a federal stablecoin charter might be structured. They also flag unresolved questions about anti-money-laundering controls, the treatment of algorithmic and foreign-issued tokens, and the boundary between stablecoins and tokenised money-market funds.

CoinDesk's year-in-review coverage on 19 July 2026 framed the milestone as a story of partial completion: the statute has reorganised the policy debate, moved billions of dollars in tokenised Treasury holdings into regulated custodians, and given banks permission to issue their own tokens, but the implementing machinery is still in consultation phase. Industry lawyers describe the regime as "live but unenforced," a phrase that captures the regulatory limbo in which large issuers such as Circle, Paxos, Ripple and a growing roster of bank-sponsored vehicles now operate.

Why the delay matters for the market

Stablecoins are no longer a niche product. Analysts cited in CoinDesk's coverage estimate that more than $200 billion in stablecoins circulate at any given time, with daily settlement volumes that rival major card networks. The bulk of that activity runs through dollar-pegged tokens, which is precisely the corner of the crypto market the GENIUS Act sought to professionalise. Without final rules, the legal distinction between a registered US issuer and an unlicensed offshore competitor remains a matter of agency discretion rather than statute.

Three practical consequences follow. First, banks remain cautious about offering custody or reserve-management services, because the prudential expectations have not been pinned down. Second, non-bank issuers are reporting reserves and obtaining attestations voluntarily, in an effort to stay on the right side of whatever the final rules eventually say. Third, foreign regimes, from the European Union's MiCA framework to Hong Kong and Singapore licensing regimes, are not waiting: their rules are in force, and the Treasury comparability process has not yet produced a list of approved jurisdictions.

The structural picture is familiar from other corners of financial regulation. Congress writes the headline statute, the agencies negotiate the technical rules, and the industry operates in the gap, building compliance infrastructure against a moving target. The difference here is speed: stablecoin issuance is growing faster than the agencies' rule-writing capacity, and the law's own deadlines have proven unenforceable.

The counter-narrative, and what the dissenters say

The official line from Treasury and the Federal Reserve is that the proposed rules are close to final and that the substance of the framework is now in front of industry and public commentators. Officials argue that careful rulemaking is preferable to a rushed final rule that has to be reopened.

The dissent comes from two directions. Banking trade groups, represented in industry filings, want tighter reserve and liquidity requirements and have pushed back against provisions they read as too permissive on non-bank access to the payment system. Consumer advocates, including some Democrats on the Senate Banking Committee, argue that the law itself was insufficiently protective and that the proposed rules compound that weakness by delaying the consumer-disclosure regime. On the other end of the spectrum, a number of crypto-industry voices argue that the rules, even in proposed form, are over-engineered and will push issuers offshore to lighter-touch regimes.

There is also a quieter critique: that the GENIUS Act's architecture, by tying stablecoins to bank balance sheets and the Treasury market, effectively folds the largest crypto-native payment instruments into the existing dollar architecture rather than building an alternative. Whether that counts as a feature or a bug depends on where one sits. For Treasury, dollar-denominated stablecoins extend the currency's reach into a parallel rails system. For some crypto founders, that integration is the opposite of what they signed up for.

What to watch next

The next milestones are procedural rather than political. Treasury must publish the foreign-jurisdiction comparability framework. The OCC must finalise its stablecoin-issuer charter. The Fed and the FDIC must complete the rules governing master-account and pass-through deposit access for non-bank issuers. Each of those rulemakings has a comment period that runs into late 2026, with final publication unlikely before the first quarter of 2027.

In the meantime, the market is voting with its feet. Tokenised Treasury products are growing, bank-sponsored stablecoins are in pilot, and offshore issuers continue to serve US customers under existing state-level money-transmission regimes. The GENIUS Act's first anniversary is not a story of failure so much as a story of unfinished business: a statute that did the easy part, naming the regime, and has left the hard part, defining how it actually works, to a regulatory apparatus still drafting.

The sources do not specify how many comments have been filed on the proposed rules, nor which foreign jurisdictions Treasury is reviewing first. Those gaps will matter as the calendar turns.

Desk note: wire coverage framed the milestone as a celebration of the law's existence; the regulatory gap was treated as a footnote. Monexus inverted the emphasis.