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 22 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. In the Federal Register, the first final document was 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.

The First Final Federal Rule: OCC, 21 October 2026

On 21 October 2026 the OCC announced a final rule implementing the Act. It “establishes requirements for permitted payment stablecoin issuers and foreign payment stablecoin issuers under the OCC's jurisdiction, as well as certain custody activities conducted by OCC-supervised entities” (OCC News Release 2026-92). According to the OCC it covers all the regulations it must write under the Act except those on the Bank Secrecy Act, anti-money laundering and OFAC sanctions, which will come in a separate rulemaking coordinated with Treasury. The OCC states that “the final rule and the GENIUS Act take effect on January 18, 2027”.

• Applications are not open yet. The OCC says it will announce in a separate news release when it begins accepting and processing applications and waiver requests from prospective permitted payment stablecoin issuers (release).
• Reporting. OCC Bulletin 2026-52 publishes revised weekly and quarterly reporting forms for public comment; subject to OMB approval they would apply from the 25 January 2027 report date (weekly) and the 31 March 2027 report date (quarterly) (OCC Bulletin 2026-52).
• Other regulators. The rule applies only to entities under the OCC's jurisdiction. Treasury, the Federal Reserve, the FDIC, the NCUA and FinCEN rules listed on the rulemaking page remain at the stage shown there.

Section 20 also allows an earlier start 120 days after final regulations are issued. Our calculation: 120 days after 21 October 2026 is 18 February 2027, later than 18 January 2027, so the 18-month date still applies, as the OCC states.

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).