The GENIUS Act Takes Effect on 18 January 2027. 16 of Its Rules Are Still Proposals

The short version: the GENIUS Act takes effect on 18 January 2027. Treasury's interim final rule of 30 September 2026 says that “the GENIUS Act takes effect on January 18, 2027, at which time it will generally be unlawful for persons to issue payment stablecoins in the United States unless they are licensed or approved as permitted payment stablecoin issuers” (Federal Register 2026-19966). It is 89 days away. Of the 20 Federal Register documents with “stablecoin” or “GENIUS” in their title, 16 are proposed rules and 1 is a final or interim final rule (read 21 Oct 2026).

Why 18 January 2027

The Act was enacted on 18 July 2025 (Public Law 119-27). Section 20 makes it effective on the earlier of 18 months after enactment or 120 days after the primary federal payment stablecoin regulators issue final implementing regulations (Act text, section 20). Treasury's rule gives 18 January 2027, the 18-month date (footnote 17).

The Rulebook Is Still Mostly Proposals

Treasury, the OCC, the FDIC, the NCUA, the Federal Reserve and FinCEN have each published proposals. The only final document among them is Treasury's interim final rule setting forms and procedures for the Stablecoin Certification Review Committee, which reviews whether a state's regime is “substantially similar” to the federal one. Every document with its comment deadline is on the rulemaking page, refreshed from the Federal Register API.

Two Later Dates

• Exchanges and other digital asset service providers. Section 3(b) makes it unlawful for them to offer or sell a payment stablecoin to a person in the United States unless it is issued by a permitted payment stablecoin issuer, “beginning on the date that is 3 years after the date of enactment” (Act text). Three years after 18 July 2025 is 18 July 2028 (our calculation).
• States. Issuers with no more than $10 billion outstanding may opt for a state regime if it is substantially similar to the federal framework. States must submit an initial certification within one year after the effective date; Treasury's rule discusses certifications “by January 18, 2028” (IFR; principles proposed in Treasury's April 2026 proposal).

Who Is Preparing

The OCC has conditionally approved 17 national bank charters involving digital assets since December 2025; 8 of the decisions describe stablecoin issuance (analysis). In New York, 6 stablecoins are on the state's Greenlist (New York page).