Editor note (remove before publishing): Previously tagged items resolved 2026-09-17 (DefiLlama USDT/USDC figures re-checked; Circle final approval date per Davis Wright Tremaine, not an OCC release; card-network stablecoin programs generalized). Also re-check the Federal Register for any GENIUS Act FINAL rules published after Sept. 9, 2026.
Last updated September 17, 2026.
In July 2025, the United States passed its first federal law for payment stablecoins, digital tokens designed to always be worth one dollar. The GENIUS Act promised to turn a crypto-market plumbing tool into something regulated enough for mainstream payments. More than a year later, regulators are still writing the rules, the law's deadlines are approaching, and the first federally chartered issuers are taking shape. Here's what has actually changed, and what hasn't, for businesses and consumers.
Key takeaways
- The GENIUS Act (Public Law 119-27) was enacted July 18, 2025 [1]. It takes effect on the earlier of January 18, 2027 (18 months after enactment) or 120 days after regulators finalize rules [2].
- Only permitted payment stablecoin issuers may issue in the U.S.; stablecoins must be backed one-for-one by high-quality reserves, redeemable at par, and may not pay interest or yield to holders [2][3].
- Payment stablecoins are not FDIC-insured and not legal tender, and issuers can't market them as government-backed [2][3].
- As of September 17, 2026, Treasury, the OCC, FDIC, NCUA, Federal Reserve, and FinCEN have issued proposed rules, but the Federal Register shows no final implementing rules yet, despite the law's one-year target [4].
- For everyday payments, the near-term change is trust and legal clarity, not a checkout revolution. Most consumer purchases still run on cards and bank transfers.
What is a stablecoin?
A stablecoin is a digital token, recorded on a blockchain, that aims to keep a stable value, usually $1. Fiat-backed stablecoins like Tether's USDT and Circle's USDC hold cash and short-term government debt as reserves; you should be able to redeem one token for one dollar.
Stablecoins are mostly used today for trading and moving money within crypto markets, cross-border transfers, and dollar access in countries with unstable currencies. Payments for ordinary goods are a small but growing slice.
How big? A third-party tracker, DefiLlama, showed roughly $268 billion in total stablecoin supply on September 17, 2026, with USDT around $183 billion and USDC around $74 billion [5]. Circle reported $73.3 billion of USDC in circulation at the end of Q2 2026, up 19% year over year [6].
What the GENIUS Act does
The law's full name is the Guiding and Establishing National Innovation for U.S. Stablecoins Act.
Who can issue
Only permitted payment stablecoin issuers (PPSIs), which must be formed in the U.S. [3]:
| Issuer type | Primary regulator (general) |
|---|---|
| Subsidiary of an insured bank or credit union | That institution's federal regulator (OCC, FDIC, Fed, or NCUA) |
| Federal qualified (nonbank) issuer | OCC |
| State qualified issuer | State regulator, if the state regime is "substantially similar"; up to $10 billion in outstanding issuance before stronger federal oversight applies [2][3] |
Foreign issuers can serve U.S. users only if Treasury finds their home regime comparable [3].
Core rules for stablecoins
According to the statute as described in the OCC's March 2026 proposal [2]:
- 1:1 reserves in cash, deposits (including at Federal Reserve Banks), short-term Treasuries, and similar highly liquid assets.
- Redemption at a fixed value (typically $1) on demand.
- Monthly reserve disclosures, examined by a registered public accounting firm.
- No interest or yield: issuers "must not pay the holder of any payment stablecoin any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention" of the stablecoin.
- Priority for holders if an issuer fails.
- No misleading claims that a stablecoin is legal tender, issued by the U.S., or government-guaranteed [3].
Legal classification
The Act excludes payment stablecoins issued by PPSIs from the definition of "security" under federal securities laws, as Circle's filings describe [6]. That removes a long-running uncertainty for issuers and the businesses that accept them.
The 2028 cutoff for unregulated coins
Beginning July 18, 2028, digital asset service providers (such as exchanges and wallets) may not offer payment stablecoins to U.S. persons unless they come from a permitted issuer or a qualifying foreign issuer [3]. That's a key date for how widely non-U.S. coins can be used here.
Where implementation stands (September 2026)
The Act asked regulators to finalize rules within a year of enactment [2]. As of September 17, 2026, a Federal Register search shows a long list of proposals and no final implementing rules [4]:
| Date | Agency | Action | Status |
|---|---|---|---|
| Sept. 19, 2025 | Treasury | Advance notice on GENIUS Act implementation [3] | Pre-proposal |
| Dec. 19, 2025 | FDIC | Approval process for bank subsidiaries issuing stablecoins [4] | Proposed (comments extended to May 18, 2026) |
| Feb. 12, 2026 | NCUA | Licensing of credit-union-subsidiary issuers [4] | Proposed |
| Mar. 2, 2026 | OCC | Main framework for issuers under OCC jurisdiction; comments due May 1, 2026 [2] | Proposed |
| Apr. 3, 2026 | Treasury | Principles for judging whether state regimes are "substantially similar" [4] | Proposed |
| Apr. 10, 2026 | FDIC; FinCEN/OFAC | Standards for FDIC-supervised issuers; AML and sanctions program rules [4] | Proposed |
| June 2026 | FinCEN, OCC, FDIC | Customer ID programs, BSA/sanctions compliance [4] | Proposed |
| July 9, 2026 | Federal Reserve | AML/CFT program rule including stablecoin issuers [4] | Proposed |
| Aug. 18, 2026 | Treasury | Rules on issuance, offer, and sale prohibitions (Section 3) [4] | Proposed |
Why it matters: if final rules don't arrive and take effect sooner, the law's January 18, 2027 date becomes the effective date by default [2]. Businesses should expect a busy few months of final rules.
First movers
- Circle said it received final approval from the OCC to establish Circle National Trust, a national trust bank, in its Q2 2026 results released August 5, 2026 [6]; law firm Davis Wright Tremaine reported the OCC granted that final approval on July 10, 2026 [9]. It also received a New York limited-purpose trust charter from NYDFS on July 31, 2026 [7].
- Circle reported its Circle Payments Network reached $14.7 billion in annualized transaction volume (trailing 30 days) at the end of Q2 2026 [6], and launched its Arc blockchain mainnet on September 16, 2026 [8]. These are company-reported figures.
What changes for everyday payments
For consumers
- More confidence, not insurance. Reserve, audit, and redemption rules make regulated stablecoins safer than before, but they're still not FDIC-insured [2]. If you hold stablecoins through an app, you're also exposed to that app's risks. Related field note
- No interest from issuers. The yield ban applies to issuers [2]. Promotions from third parties, such as exchanges, raise separate legal questions that regulators are still addressing.
- Irreversible payments. Like instant bank payments, stablecoin transfers generally can't be charged back. Scams remain a risk. Related field note
- Checkout is still mostly cards. Your card or bank app may use stablecoins behind the scenes for settlement without you noticing.
For businesses
Where stablecoins may help:
| Use case | Potential benefit | Watch out for |
|---|---|---|
| Cross-border supplier payments | 24/7 settlement, fewer intermediaries | Off-ramp fees and FX spreads, recipient's local rules |
| Contractor and creator payouts abroad | Fast delivery to digital wallets | Tax reporting, sanctions screening |
| Treasury movement between entities | Weekend settlement | Accounting treatment, custody risk |
| Accepting stablecoins from customers | Lower fees than cards in some cases | No chargebacks (customers may prefer cards), volatility of non-permitted coins |
Some payment companies offer or are developing stablecoin settlement and payout options; check each provider's current availability. Compare the all-in cost, including conversion to dollars in a bank account, against ACH, instant payments, and wires. Related field note Related field note
Questions to ask a stablecoin payment provider
- Is the stablecoin issued by a permitted issuer (or will it be once rules take effect)?
- Who holds the tokens: you, or the provider as custodian? What happens if the provider fails?
- What are the on-ramp and off-ramp costs to and from dollars?
- How are sanctions and AML checks handled?
- How are errors and fraud handled when transfers are irreversible?
What to watch next
- Final rules from the OCC, FDIC, NCUA, Fed, Treasury, and FinCEN before the January 18, 2027 statutory backstop [2].
- Treasury's decisions on state-regime equivalence and foreign-issuer comparability [3][4].
- The July 18, 2028 cutoff for service providers offering non-permitted stablecoins [3].
- Bank-issued stablecoins and tokenized deposits as banks weigh their own products.
FAQ
Is the GENIUS Act in effect? It was enacted July 18, 2025, but its main framework takes effect the earlier of January 18, 2027 or 120 days after final regulations [1][2]. As of September 17, 2026, rules are still proposed [4].
Are stablecoins FDIC-insured under the GENIUS Act? No. Payment stablecoins can't be represented as FDIC-insured, legal tender, or government-guaranteed [2][3].
Can I earn interest on stablecoins? Permitted issuers may not pay holders interest or yield solely for holding the stablecoin [2]. Treat any third-party "rewards" offer with caution and read its terms.
Is USDC compliant with the GENIUS Act? Circle says USDC will be issued by a permitted issuer and has received OCC final approval for a national trust bank [6]. Compliance will be judged against final rules once issued.
Will stablecoins replace credit cards? Not soon. Cards offer credit, rewards, and chargebacks. Stablecoins are more likely to grow first in cross-border and business payments. Related field note
Is a stablecoin the same as a digital dollar from the Fed? No. Stablecoins are issued by private companies. A central bank digital currency would be issued by the Federal Reserve, and the U.S. has not issued one.
Sources
- Department of the Treasury, FinCEN, "Bank Secrecy Act Advisory Group; Solicitation of Application for Membership" (referencing GENIUS Act enactment July 18, 2025), Federal Register, https://www.federalregister.gov/documents/2026/02/25/2026-03707/bank-secrecy-act-advisory-group-solicitation-of-application-for-membership, Feb. 25, 2026, accessed 2026-09-17.
- Office of the Comptroller of the Currency, "Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency" (proposed rule), Federal Register, https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the, Mar. 2, 2026, accessed 2026-09-17.
- Department of the Treasury, "GENIUS Act Implementation" (advance notice of proposed rulemaking), Federal Register, https://www.federalregister.gov/documents/2025/09/19/2025-18226/genius-act-implementation, Sept. 19, 2025, accessed 2026-09-17.
- Federal Register, document search for "GENIUS Act" (results including FDIC, NCUA, Treasury, FinCEN/OFAC, OCC, and Federal Reserve proposals, Dec. 2025–Sept. 2026), https://www.federalregister.gov/documents/search?conditions%5Bterm%5D=%22GENIUS+Act%22, accessed 2026-09-17.
- DefiLlama, "Stablecoins," https://stablecoins.llama.fi/stablecoins, accessed 2026-09-17. (Third-party data tracker.)
- Circle, "Circle Reports Second Quarter 2026 Results," https://www.circle.com/pressroom/circle-reports-second-quarter-2026-results, Aug. 5, 2026, accessed 2026-09-17. (Company source.)
- Circle, "Circle Granted Trust Charter by the New York Department of Financial Services," https://www.circle.com/pressroom/circle-granted-trust-charter-by-the-new-york-department-of-financial-services, July 31, 2026, accessed 2026-09-17. (Company source.)
- Circle, "Circle Launches Arc Mainnet," https://www.circle.com/pressroom/circle-launches-arc-mainnet-an-economic-operating-system-for-the-internet, Sept. 16, 2026, accessed 2026-09-17. (Company source.)
- Davis Wright Tremaine, "OCC's Recent Charter Approvals Signal Momentum for Digital-Asset Bank Charters," https://www.dwt.com/blogs/financial-services-law-advisor/2026/08/occ-signals-digital-asset-charter-momentum, Aug. 5, 2026, accessed 2026-09-17.
Disclaimer: This article is for educational purposes only and is not financial, investment, legal, or tax advice. Stablecoins carry risks, including issuer, custody, and fraud risks, and are not FDIC-insured. Regulations implementing the GENIUS Act are still being finalized. Consult qualified professionals before using stablecoins in your business.