Answers › Stablecoins: the GENIUS Act
When does the GENIUS Act take effect, and what implementing rules have the OCC and Treasury issued so far?
Plan on January 18, 2027 as the effective date, unless an earlier final regulation moves it. The OCC has issued a final rule, while Treasury so far has only a proposal.
What the rule says:
- The Act takes effect on the earlier of 18 months after enactment or 120 days after the primary Federal payment stablecoin regulators issue any final regulations implementing it (Sec. 20 of Pub. L. 119-27). It was enacted July 18, 2025, so the 18-month date is January 18, 2027. The 120-day trigger can only bring the date forward.
- OCC: a final rule implementing the Act for the issuance of stablecoins by entities subject to the OCC's jurisdiction was published October 23, 2026, and is effective January 18, 2027. The OCC proposed it on March 2, 2026.
- Treasury: a proposed rule published August 18, 2026 would implement section 3 of the Act, which covers the statutory prohibitions and limitations on payment stablecoin issuance, offer, and sale in the United States. Comments closed October 19, 2026. It is a proposal only, and we see no Treasury final rule.
What we would look at:
- Whether any final regulation was issued before September 20, 2026, because only that would make the 120-day date fall before January 18, 2027. We cannot confirm one. The Act's text also does not say whether a final rule from one regulator alone starts the 120 days.
- If you issue stablecoins as an entity under OCC jurisdiction, review the OCC final rule now.
- Track Treasury's proposal rather than treating it as binding.
- Check whether your own primary Federal payment stablecoin regulator has issued a final rule, since that could affect timing.
Sources
- GENIUS Act, Pub. L. 119-27: https://www.govinfo.gov/content/pkg/PLAW-119publ27/html/PLAW-119publ27.htm
- Federal Register document 2026-16796: https://www.federalregister.gov/documents/2026/08/18/2026-16796/genius-act-regulations-on-payment-stablecoin-issuance-offer-and-sale
- Federal Register document 2026-21706: https://www.federalregister.gov/documents/2026/10/23/2026-21706/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the
This answer is general information, not legal advice. Forteris is not a law firm.
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