US GENIUS Act proposed rules

The GENIUS Act, enacted on July 18, 2025, establishes the federal framework for regulating payment stablecoins in the United States. The law directs the Treasury Department to issue specific regulations that define who can issue these digital assets and what must back them. On March 2, 2026, the Federal Register published the proposed rules implementing this framework, marking the first concrete steps toward federal oversight of the stablecoin market Federal Register.

The GENIUS Act generally prohibits any person other than a permitted payment stablecoin issuer from issuing a payment stablecoin in the United States.

Under the proposed rules, only entities that obtain a federal charter or permit can issue payment stablecoins. This effectively bars private companies, non-bank fintechs, and decentralized protocols from issuing USD-pegged tokens for payments unless they meet strict banking standards. The Office of the Comptroller of the Currency (OCC) is among the agencies tasked with enforcing these new issuer requirements, ensuring that only regulated financial institutions can provide this infrastructure OCC.

Reserve standards are equally stringent. The proposed rules require issuers to maintain reserves backing outstanding stablecoins on at least a one-to-one basis. These reserves are restricted to highly liquid, low-risk assets, including US dollars, Federal Reserve notes, and funds held at insured or regulated depository institutions. This approach aims to eliminate the credit and liquidity risks associated with commercial paper or corporate bonds that have historically backed some stablecoins.

The Treasury Department’s proposal emphasizes transparency and consumer protection. Issuers will need to undergo regular audits and provide public reports on their reserve composition. By limiting reserve assets to cash and cash equivalents, the regulations seek to ensure that stablecoins remain stable and redeemable at par value, even during market stress. This framework represents a significant shift from the current self-regulatory environment to a supervised banking model.

EU MiCA reserve requirements

The Markets in Crypto-Assets (MiCA) regulation establishes a bespoke regime for digital assets in the European Union. Implemented fully in 2024, MiCA distinguishes between two primary stablecoin categories: Asset-Referenced Tokens (ARTs) and E-Money Tokens (EMTs). This section details the reserve requirements specific to these tokens under the EU framework.

Asset-Referenced Tokens (ARTs)

ARTs are stablecoins pegged to the value of assets, such as a basket of currencies or commodities. The reserve requirements for ARTs are among the strictest in global crypto regulation. Issuers must hold reserves that are "adequate, appropriate, and proportionate" to the value of the tokens in circulation. These reserves must be segregated from the issuer's own assets to protect token holders in the event of insolvency.

The reserves must be held in cash, bank deposits, or highly liquid assets. Crucially, the value of the reserves must equal or exceed the value of the outstanding ARTs at all times. Issuers are required to publish regular reports on the composition and value of these reserves, ensuring transparency for regulators and users alike.

E-Money Tokens (EMTs)

EMTs are pegged to a single official currency, such as the euro. They function similarly to traditional electronic money. Under MiCA, EMT issuers must hold reserves equal to the value of the EMTs issued. These reserves must be kept in separate accounts at credit institutions or central banks.

The primary goal is to ensure that EMT holders can redeem their tokens for the underlying fiat currency at any time, at par value. This redemption right is fundamental to the EMT model. Issuers must also maintain robust governance and risk management procedures to safeguard these reserves against loss or misuse.

Segregation and Redemption

Both ART and EMT issuers face strict segregation rules. The law mandates that reserve assets are held in trust or in separate accounts, distinct from the issuer's operational funds. This structural separation prevents commingling and ensures that token holders have a prior claim on the reserves.

Redemption rights are non-negotiable. Holders must be able to redeem their tokens at any time without undue delay or cost. This liquidity guarantee is a core pillar of MiCA's consumer protection strategy, aiming to build trust in digital assets while minimizing systemic risk.

US vs EU compliance differences

The regulatory frameworks in the United States and the European Union diverge significantly in their approach to stablecoin oversight. While both jurisdictions aim to mitigate financial risk, they establish distinct eligibility criteria for issuers and define reserve assets differently. Understanding these structural differences is essential for operators planning to launch or manage stablecoins across borders.

The US GENIUS Act, with its proposed rule published in the Federal Register on March 2, 2026, restricts the issuance of payment stablecoins to permitted entities, effectively creating a narrow, bank-like pathway for compliance. In contrast, the EU’s Markets in Crypto-Assets (MiCA) regulation establishes a bespoke regime for both Asset-Referenced Tokens (ARTs) and E-Money Tokens (EMTs), offering a broader, passporting-based framework for authorized crypto-asset service providers.

The table below outlines the core distinctions between these two regimes as of 2026.

Key 2026 compliance deadlines

The regulatory framework for stablecoins is moving from legislative text to operational rules. Both the United States and the European Union have established specific timelines for comment periods, final rule adoption, and enforcement phases in 2026.

United States: GENIUS Act Implementation

The Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA) are leading the charge on US compliance. The FDIC issued its Notice of Proposed Rulemaking to establish guidelines under the GENIUS Act on April 7, 2026. This proposal generally requires Permitted Payment Stablecoin Issuers (PPSIs) to redeem stablecoins within two business days.

Following the FDIC's lead, the NCUA published its own proposed rule for PPSI applications. The comment period for the NCUA's proposal is scheduled to close on April 13, 2026. These dates mark the beginning of the formal rulemaking phase, where industry feedback will shape the final regulatory requirements.

European Union: MiCA Enforcement Phases

In the EU, the Markets in Crypto-Assets (MiCA) regulation continues its phased rollout. While general provisions are already in effect, specific rules for stablecoins and crypto-asset service providers have distinct deadlines. Financial institutions must align their reserve management and reporting systems with MiCA standards throughout 2026 to avoid non-compliance penalties.

Stablecoin compliance checklist

Issuers preparing for the 2026 regulatory landscape must align with two primary frameworks: the GENIUS Act in the United States and MiCA in the European Union. The following checklist outlines the core operational requirements for compliance.

Reserve and Liquidity Requirements

Reserves must be held in segregated accounts to protect user funds. Under the GENIUS Act, reserves backing outstanding payment stablecoins must maintain at least a one-to-one ratio with specified low-risk assets, including US dollars and federal reserve notes [src-serp-1]. MiCA requires EMTs and ARTs to hold assets in a segregated portfolio, ensuring immediate redemption capabilities for token holders [src-serp-8].

Issuer Licensing and Authorization

Issuers must obtain specific authorization before launching a stablecoin. The GENIUS Act prohibits any person other than a permitted payment stablecoin issuer from issuing a payment stablecoin in the United States [src-serp-1]. In the EU, issuers must secure authorization from their national competent authority under MiCA, demonstrating robust governance and capital adequacy.

Redemption and Reporting Obligations

Timely redemption is mandatory. Issuers must honor redemption requests from holders at par value without undue delay. Regular reporting to regulators is also required, including details on reserve composition, issuance volumes, and redemption activity. These reports ensure transparency and allow regulators to monitor systemic risk.

Governance and Consumer Protection

Strong governance structures are essential. Issuers must implement clear policies for risk management, conflict of interest, and consumer complaints. MiCA mandates specific consumer protection measures, including clear information disclosure and complaint handling procedures. The GENIUS Act similarly requires issuers to maintain adequate safeguards for users.

Frequently asked: what to check next

What is the deadline for US stablecoin issuers to comply with the GENIUS Act?

The GENIUS Act was enacted on July 18, 2025. Proposed rules were published in the Federal Register on March 2, 2026. Final rules and specific compliance deadlines are determined through the subsequent rulemaking process involving the Treasury, OCC, FDIC, and NCUA. Issuers should monitor Federal Register notices for final adoption dates.

How do EU MiCA reserve requirements differ from US proposals?

MiCA distinguishes between E-Money Tokens (EMTs) and Asset-Referenced Tokens (ARTs), requiring segregated reserves for both. The US GENIUS Act proposed rules focus on "permitted payment stablecoin issuers" (typically banks) and require reserves in cash or Federal Reserve deposits. MiCA allows a broader range of highly liquid assets for ARTs, while US rules are stricter regarding the type of backing assets.

Can non-bank entities issue stablecoins under the US GENIUS Act?

The proposed rules under the GENIUS Act generally restrict issuance to entities with federal charters or permits, effectively limiting the market to regulated financial institutions. Non-bank fintechs and decentralized protocols would need to meet strict banking standards or operate within specific exemptions, which are not yet fully defined in the current proposed rules.