Overview
- Federal agencies failed to issue final implementing rules by the one-year statutory deadline on July 18, 2026, leaving key requirements unset for issuers and banks.
- Major rule packages covering reserves, redemptions, capital, custody, liquidity, and customer-identification/AML remain in proposal or comment stages and open for feedback into August and September.
- The stablecoin market has continued to grow above $300 billion while firms and incumbents push forward with operational plans such as Visa's enterprise platform, conditional bank charters, and new products like Tether’s USA₮.
- Tether faces a transitional risk because its global USDT could be blocked from U.S. platforms by mid-2028 if it cannot meet GENIUS Act standards or obtain a Treasury reciprocity finding, forcing a two-token strategy for the U.S.
- Agencies still can finalize rules before the law takes effect on January 18, 2027 or 120 days after final rules, but the compressed timeline raises the chance that well-resourced firms will lock in market access while smaller issuers confront higher compliance costs.