US issues stablecoin rules taking effect on 18 January 2027
Key Facts
The US Office of the Comptroller of the Currency issued a final rule implementing the GENIUS Act governing payment stablecoins, with both the rule and the law taking effect on 18 January 2027, according to an OCC statement. The rule sets requirements for issuing these stablecoins and related activities within the regulator's jurisdiction, covering banking and nonbank entities. Its scope extends to foreign payment stablecoin issuers subject to the OCC's jurisdiction, according to its regulatory bulletin. The move follows the law's enactment on 18 July 2025 and establishes implementing rules for the legislative framework governing these stablecoins. The OCC had issued a regulatory proposal to implement the law on 25 February 2026 before proceeding to the announced final version.
At the heart of the requirements, the law mandates 100% reserve backing with liquid assets, according to a White House fact sheet on the legislation. Assets eligible for that backing include US dollars or short-term Treasury securities, according to the fact sheet. The law also requires issuers to publicly disclose the composition of their reserves monthly, alongside compliance with the backing requirement. Comptroller of the Currency Jonathan Gould said the framework sets "strong standards for reserve backing, redemption and risk management," according to the OCC statement announcing the final rule. The rule also includes asset custody requirements, according to the OCC's regulatory bulletin on the scope of implementation.
In a change from the earlier proposal, the OCC removed from the final rule the rebuttable presumption concerning arrangements for paying yield through other parties. That presumption had been part of the proposed treatment of these arrangements involving stablecoin yields, according to the final rule document. Despite removing it, the OCC retained its authority to address circumvention of the prohibition on issuers paying yield. The prohibition applies equally to institutional and individual holders of payment stablecoins, according to the same document. Bank Secrecy Act, anti-money laundering and Office of Foreign Assets Control sanctions requirements will be addressed through a separate rulemaking process in coordination with the Treasury Department, according to the regulatory bulletin.
On licensing, the OCC said issuing a payment stablecoin in the United States without permitted issuer status carries criminal penalties. The OCC's guidance, meanwhile, allows issuers to request an exemption from the requirements of the law or the final rule during the transition period. This process requires the issuer to have a substantially complete application pending before the OCC, according to the bulletin on licensing applications and exemptions. An issuer meeting that condition must submit a written exemption request to the regulator. The maximum temporary exemption permitted by the law is 12 months, according to the OCC's guidance governing these requests.
The opening of licensing and exemption applications is subject to approval from the Office of Management and Budget, according to the OCC's filing guidance. The required approval concerns information collection associated with the application forms applicants will use in this regulatory process. The OCC said it would announce the opening of applications in a separate statement after obtaining that approval. In parallel, the notice on information collection for licensing and registration applications allows comments on the information collection within a period set by the OCC. That period is 30 days from the notice's publication in the Federal Register, according to the text of the notice concerning licensing and registration applications.
The final rule also includes audit and supervision standards for covered entities, according to the OCC's regulatory bulletin. Its requirements also include reporting, and the OCC has set dates for the start of information collection for weekly and quarterly forms. Information collection for the weekly report form begins with the report dated 25 January 2027, according to the OCC's reporting bulletin. Information collection for the quarterly report form begins with the report dated 31 March 2027, according to the same bulletin. Information collection for both forms on the specified dates remains subject to approval from the Office of Management and Budget.