GENIUS Act Is Officially Law — Now What? The Most Important Deadlines Stablecoin Businesses Should Know

By: Moish E. Peltz, Esq. and Kyle M. Lawrence, Esq.

The fight to regulate U.S. stablecoins was never going to be easy. In a Congress where even consensus bills often die quietly, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act had to survive an unusually public and procedurally challenging path. 

As Kristin Smith, President of the Solana Policy Institute, explained on the Block & Order podcast in June, “Passing a bill is a really, really hard thing — creating a new regulatory framework from scratch is very rare. It only happens maybe once a decade across all sectors.” Unlike most legislation that gets tucked into must-pass packages, this one had to move through regular order on the Senate floor — a process designed to be hard. And yet, with bipartisan cooperation and support from the White House, it made it to the President’s desk.

That in itself is a big deal for the crypto industry, showing that digital assets can command real legislative momentum in Washington. Now that the law is on the books, Smith says, “the clock is ticking” — and this post is your guide to the most important deadlines and timelines stablecoin businesses need to have on their radar. “President Trump’s signing of the GENIUS Act kicked off an 18-month implementation period that will reshape the stablecoin landscape. While the Act takes effect by January 2027 at the latest, the real work starts now,” said Smith. 

The First Federal Stablecoin Framework

On July 18, 2025, President Trump signed the GENIUS Act into law, establishing the first federal framework for U.S. dollar–pegged payment stablecoins. For businesses issuing, transacting in, or planning to launch a stablecoin, this law doesn’t just reshape the compliance landscape — it sets a precedent. Smith, who’s been advocating for crypto in Washington for over two decades, described it as “the most important legislative priority” for the space, given the lack of existing federal authority over these assets and their potential to transform payments.

At a high level, the GENIUS Act ensures that only permitted issuers can offer U.S. dollar–pegged stablecoins. These permitted issuers include a subsidiary of an insured bank, a non-bank entity approved by the Office of the Comptroller of the Currency (OCC), or a state-licensed non-bank issuer whose stablecoin market capitalization is under $10 billion. 

The mandate for those issuers is simple but strict: every stablecoin in circulation must be backed 1:1 by high-quality liquid assets, such as U.S. currency, insured bank deposits, short-term Treasuries, certain repurchase agreements, money market funds, or similarly liquid instruments. And issuers must publish monthly public disclosures detailing their reserves.

How and When the Law Takes Effect

Even with those broad strokes set, the law leaves significant details to regulators. It becomes effective on the earlier of 18 months after enactment or 120 days after final implementing rules are issued, a built-in safeguard against rulemaking delays. Agencies must notify Congress as soon as they begin processing applications. “We should see proposed rules within 6-12 months,” Smith summarized. 

Treasury, meanwhile, has two years to determine which foreign jurisdictions meet “substantially similar” standards for cross-border reciprocity. 

State Licensing: Annual Filings and the $10B Threshold

The state licensing pathway comes with its own timelines. States have one year to certify to the Treasury that their framework is substantially similar to the OCC’s, with annual recertifications thereafter. If a state-licensed issuer’s market cap crosses $10 billion, it has 360 days to transition to federal oversight or stop issuing new tokens. According to Smith, “there is both opportunity and urgency — those under state frameworks have temporary relief if they stay below $10 billion in issuance, but states must achieve federal certification within one year of the effective date.” 

Federal Applications: Shorter Deadlines, Higher Stakes

For non-bank entities applying to the OCC, the timelines are even tighter. Once an application is deemed complete, the OCC has 120 days to decide — and if it misses the deadline, the application is automatically approved. Denials trigger a 30-day appeal window, and if a hearing is requested, it must be scheduled within 30 days, with a final decision issued within 60 days after that. The OCC must also publish an annual report to Congress listing any charters pending six months or more.

How the Law Treats Banks

Although banks aren’t the target audience for this bill, the law does also address them. An insured depository institution can issue stablecoins directly without a new charter, so long as it meets the GENIUS reserve, redemption, and disclosure requirements. If a bank issues through a subsidiary, that entity must seek approval from the bank’s federal regulator.

Looking Ahead: Studies and Reports

The Act also looks ahead to unresolved policy questions. Treasury, alongside the Fed, SEC, OCC, and FDIC, must deliver a report within one year on algorithmic or “endogenous” stablecoins — those not backed by conventional reserves — assessing their designs, reserve models, and risks. In addition, regulators are required by the law to study how insolvency proceedings for stablecoin issuers might work, with a report due in three years.

Why These Deadlines Matter

All told, the GENIUS Act sets a structured but still-evolving compliance environment. Stablecoin businesses must immediately prepare to meet the 1:1 reserve standard and monthly disclosure requirements while staying nimble as agencies fill in the operational blanks over the next 18 months. As Smith emphasized on Block & Order, this is “worth the ups and downs” because a framework passed through such a rigorous process is built to last.

For now, issuers and platforms should be auditing reserve practices, redemption workflows, and licensing strategies. They should also assign dedicated counsel — internal or external — to monitor each agency’s rulemaking docket and to engage in public comment periods where the fine print is still up for debate.

Key Compliance Milestones at a Glance

• GENIUS Act Effective Date: 18 months after enactment or 120 days post-final rulemaking — whichever comes first.

• Treasury Certification (State Pathway): Treasury will approve which states can regulate stablecoins under $10B within one year.

  • $10B Threshold for State Issuers: stablecoin issuers whose token has a higher than $10B market cap must transition to federal oversight within 360 days.

• Federal Application Decisions: Non-bank OCC applicants will receive a decision within 120 days of submitting their application to be a federally regulated stablecoin issuer. 

• International Reciprocity: Treasury will determine which foreign jurisdictions have sufficient stablecoin regulation schemes within 2 years. Tokens from companies based in those jurisdictions can still be available on exchanges used by US citizens. 

The GENIUS Act is a turning point for U.S. stablecoins — not just because of the rules it sets, but because of the political capital it took to get here. For stablecoin businesses, that means the framework is unlikely to disappear anytime soon. The challenge now is to navigate its deadlines and moving parts with the same urgency that lawmakers finally brought to getting it passed.

If your organization issues, transacts in, or plans to launch a stablecoin, Falcon Rappaport & Berkman’s Kyle Lawrence and Moish Peltz are ready to help you build a compliance path that aligns with GENIUS Act obligations and anticipates the evolving regulatory backdrop.

DISCLAIMER: This summary is not legal advice and does not create any attorney-client relationship. This summary does not provide a definitive legal opinion for any factual situation. Before the firm can provide legal advice or opinion to any person or entity, the specific facts at issue must be reviewed by the firm. Before an attorney-client relationship is formed, the firm must have a signed engagement letter with a client setting forth the Firm’s scope and terms of representation. The information contained herein is based upon the law at the time of publication.