The clock the GENIUS Act started in July 2025 was supposed to hand the industry a finished rulebook by now. It did not. The deadline for most of the stablecoin rules the law requires ran out on July 18, 2026, one year after the statute took effect, and the final stablecoin rules still do not exist. What sits in their place is a stack of drafts, open comment windows, and a market that kept minting coins the entire time.
That gap is the story. The bill signing got wall-to-wall coverage last summer. Far fewer people are counting the months since the rules were actually due.
The one-year clock ran out on July 18
The GENIUS Act became effective on July 18, 2025. The statutory timeline gave regulators one year from that date to promulgate the bulk of the implementing final rules, which set the hard mark at July 18, 2026. That date passed without a single finalized rule from the agencies that share the work. crypto.news reported the miss in late August, noting the OCC now wants a final rule out by November.
Blowing a rulemaking deadline is ordinary in Washington. What makes this one worth watching is the pile of money sitting unregulated while the stablecoin rules get finished, and the fact that the law's own start date is chained to when those rules land.
What the agencies have on paper
The agencies have produced proposed stablecoin rules, not final ones. The OCC issued its proposed rule for payment stablecoin issuers on February 25, 2026, setting out reserve, redemption, custody, and capital standards under a new part of its regulations. Treasury moved later. On August 18, 2026 it published its own proposed rule in the Federal Register, covering foreign issuance and third-party sales, with public comment open until October 19, 2026.
| Rulemaking | Regulator | Stage | Key date |
|---|---|---|---|
| Payment stablecoin issuer standards | OCC | Proposed | Feb 25, 2026 |
| Foreign issuance, offer and sale | Treasury | Proposed, comment open | Comments to Oct 19, 2026 |
| Bank Secrecy Act and sanctions terms | Treasury and OCC | Not yet issued | Separate future rulemaking |
The two proposals cover different ground, which is part of why the coordination has dragged. Reserve rules, licensing, and reporting sit mostly with the banking regulators. The foreign-issuer prohibitions sit with Treasury. Bank Secrecy Act and sanctions terms have been carved off into yet another rulemaking that has not surfaced at all.
Supply kept growing while the drafts sat
While the stablecoin rules stayed in draft, the thing they govern kept growing. Total stablecoin supply stood near $303 billion on August 22, 2026, according to CryptoRank, with Tether's USDT holding roughly 60 percent of the pool. That is real money already circulating under a regime that is still, for the moment, hypothetical. Coinliva tracked the same market as it pushed past $320 billion earlier in the year, with Tether's share slipping as Circle's USDC gained.
The law meant to sit under all of this is precise about what it will demand. Issuers will have to back every token one-to-one with cash and short-term Treasuries, hold a federal or state license, and disclose reserves monthly. Any issuer with more than $50 billion in coins outstanding will face annual audited financials. The two biggest dollar stablecoins already clear that size threshold on their own. None of those requirements can be enforced today.
When the stablecoin rules start to bite
The delay matters most at the next step, because the law's effective date is chained to it. The GENIUS Act takes full effect on the earlier of two triggers: January 18, 2027, which is eighteen months after enactment, or 120 days after the primary regulators finalize their rules. The one-year target for the final stablecoin rules already slipped, and with the OCC aiming at November, the 120-day path now points into early 2027 rather than late 2026. crypto.news placed the practical effective date around March 2027. Whichever trigger fires first, the January 18, 2027 backstop is the date to circle if the drafts keep sliding.
One slice of the law is already live. The prohibition on certain foreign-issued stablecoins took effect the day the Act was signed. The broader restriction on service providers offering non-compliant payment stablecoins does not arrive until July 18, 2028, three years after signing. So enforcement lands across three separate points, and the middle one, the piece that licenses and polices US issuers, is exactly the part still stuck in draft.
The stablecoin law is further along than the wider market-structure push, where the CLARITY Act still carries long odds in the Senate. The United States is also not alone in writing rules after the fact. Britain's central bank spent months on a plan to cap individual stablecoin holdings before it was forced to walk it back, and Japan built its own stablecoin framework on a separate schedule.
For holders and issuers, nothing changes in the near term. Dollar stablecoins keep running on private attestations and state money-transmitter licenses, the same setup that predated the federal law. The dates to watch are Treasury's October 19 comment deadline and whatever the OCC finalizes in November. The 120-day countdown to enforcement does not begin until the final stablecoin rules actually print.