A year ago, on July 18, 2025, the United States signed the GENIUS Act into law — the country's first federal framework for dollar-pegged stablecoins. Regulators got exactly twelve months to write the rules. That clock ran out on July 18, 2026, and not one of the eight required rules has been finalized.
The Office of the Comptroller of the Currency, the Treasury Department, FinCEN and OFAC were supposed to hammer out reserve, capital, reporting and anti-money-laundering requirements for stablecoin issuers. Instead of final text, regulators published three more proposed rules on June 22 — with comment periods that run past the deadline itself. That timing alone signaled the agencies knew they wouldn't make it.
The law carries no penalty for missing the date and doesn't trigger an automatic transition period. Instead, full implementation kicks in on whichever of two dates comes first:
- 120 days after regulators actually finalize the rules, or
- January 18, 2027 — eighteen months after the law was signed.
FinCEN's own internal paperwork reportedly already assumes the second scenario.
This isn't unprecedented. After Dodd-Frank passed in 2010, regulators blew roughly 40% of its statutory deadlines, and some rules took years to finish. The stakes are higher for stablecoins: until the rules exist, banks and fintechs don't know the exact reserve and reporting bar they'll be held to, yet they're building products anyway.
None of this has slowed the market down. Circle already picked up a federal OCC trust bank charter, Japan's Sony Bank won OCC approval for a dollar stablecoin, and Visa rolled out a platform last week that lets banks issue their own stablecoins. Every one of them is operating on rules that could still shift under their feet — the federal framework simply isn't locked in yet.
The result is an odd standoff: the law is technically in force, but the instruction manual is still being written. For stablecoin issuers, that means up to another year and a half of building on assumptions, with real risk the ground rules change after they've already committed.
