Implementation Timeline
Key deadlines for regulators and the industry after enactment. The GENIUS Act was signed into law on July 18, 2025.
18 months after enactment, or 120 days after final regulations — whichever is earlier
Primary federal regulators must issue implementing regulations within 1 year
AML innovation recommendations due within 6 months
Law Implementation
These are deadlines for regulators to implement the law — rulemakings, reports, and studies that must be completed regardless of any specific application.
6-12 Months5 items
Primary Rulemaking Deadline
Federal banking regulators must issue regulations to implement the GENIUS Act through notice-and-comment rulemaking.
Each primary Federal payment stablecoin regulator, the Secretary of the Treasury, and each State payment stablecoin regulator must promulgate regulations.
Foreign Issuer Rules
Treasury must issue rules for how foreign payment stablecoin issuers can register and operate in the U.S.
Rules covering comparability determinations, registration requirements, and reciprocal arrangements with foreign jurisdictions.
First Annual Industry Report
Regulators must submit their first annual report on the payment stablecoin industry to Congress.
Report covers trends in stablecoin activities, number of applications and approvals, and potential financial stability risks.
Non-Payment Stablecoin Study
Treasury must complete a study of non-payment stablecoins (including algorithmic/endogenously collateralized coins).
Study examines categories of non-payment stablecoins, their risks, reserve compositions, algorithms, governance, and consumer disclosures.
Interoperability Standards Assessment
Regulators must assess and may prescribe standards for stablecoin interoperability with other issuers and the broader digital finance ecosystem.
Done in consultation with NIST and other standard-setting organizations. Covers compatibility with blockchains (permissioned or public).
1+ Years4 items
Act Takes Effect
The GENIUS Act becomes fully effective. All provisions are in force, and issuers must comply with requirements.
Effective 18 months after enactment, OR 120 days after final regulations are issued — whichever comes first.
Foreign Reciprocal Arrangements Target
Treasury should complete reciprocal arrangements with comparable foreign jurisdictions.
Bilateral agreements to allow foreign issuers from qualified jurisdictions to operate in the U.S., and U.S. issuers to operate abroad.
FinCEN AML Guidance/Rulemaking
FinCEN may issue guidance or rules on innovative AML approaches for payment stablecoin issuers.
Based on the results of voluntary pilot programs, FinCEN may formalize successful AML innovation approaches.
Insolvency Framework Study
Federal regulators must complete a study of potential insolvency proceedings for stablecoin issuers.
Examines gaps in bankruptcy laws, ability to pay stablecoin holders in full during insolvency, and whether additional authorities are needed.
Application & Review Timelines
These deadlines apply to specific applications, enforcement actions, or reviews — not the overall law implementation. They start from when an application is filed or action is initiated.
Federal Issuer Application
sec-5 →Timeline for approval of a new federal qualified payment stablecoin issuer
State Certification
sec-4 →Timeline for state regulatory regime certification
Foreign Issuer Registration
sec-18 →Timeline for foreign payment stablecoin issuer registration
Enforcement Actions
sec-6 →Timeline for regulatory enforcement against issuers
All Sections Requiring Rulemaking
24 sections in the bill require agencies to issue regulations: