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Stablecoins10 min read

The GENIUS Act, read from the enacted text for businesses that accept stablecoins.

Signed on 18 July 2025, the GENIUS Act (Public Law 119-27) sets the US rules for payment stablecoins such as USDC: who may issue them, what reserves back them and what issuers must publish. It takes effect on 18 January 2027 at the latest, and as of 15 October 2026 its implementing rules are still proposals, apart from one procedural interim rule from Treasury. Its obligations fall on issuers and on "digital asset service providers", and the word "merchant" appears in it only once, in an unrelated phrase. This post is not legal advice.

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What is the GENIUS Act?When does the GENIUS Act take effect?Have the GENIUS Act rules been finalised?What does the GENIUS Act require of stablecoin issuers?Where do businesses that accept stablecoins appear in the GENIUS Act?What does a USDC payment through Fianto involve?What should a business watch for next?SourcesQuestions
TL;DR
  • The GENIUS Act became law on 18 July 2025 and takes effect on the earlier of 18 January 2027 or 120 days after final rules from the primary federal regulators.
  • As of 15 October 2026 the Federal Register shows proposed rules from the OCC, FDIC, Federal Reserve, NCUA, Treasury and FinCEN, and one Treasury interim final rule on state certification forms. No final rule from a primary federal regulator.
  • Issuers must hold reserves at least 1 to 1, publish their make-up monthly and pay holders no interest. A ban on service providers selling unpermitted stablecoins starts on 18 July 2028.

What is the GENIUS Act?

The GENIUS Act is the US federal law that licenses and supervises the issuers of payment stablecoins. Its full name is the Guiding and Establishing National Innovation for U.S. Stablecoins Act. It began as S. 1582, passed the House on 17 July 2025 and was approved on 18 July 2025 as Public Law 119-27. Most of it is codified at 12 U.S.C. 5901 and the sections after it.

A payment stablecoin, in section 2(22), is a digital asset that is used, or designed to be used, as a means of payment or settlement, whose issuer is obliged to convert, redeem or repurchase it for a fixed amount of money and says it will keep a stable value against that amount. A national currency, a bank deposit and a security are excluded from the definition.

Everything below is quoted from the enacted text or cited by section. This is not legal advice, and it does not say whether the Act applies to your business: that depends on facts only a lawyer who knows them can weigh.

When does the GENIUS Act take effect?

The GENIUS Act takes effect on 18 January 2027 unless final rules arrive early enough to move the date forward, and as of 15 October 2026 they cannot. Section 20 sets the date as the earlier of "the date that is 18 months after the date of enactment of this Act" or "the date that is 120 days after the date on which the primary Federal payment stablecoin regulators issue any final regulations implementing this Act."

Eighteen months after 18 July 2025 is 18 January 2027. A final rule issued today would start a 120-day clock ending on 12 February 2027, later than that, so the 18-month date comes first. Treasury reaches the same date in footnote 10 of its August 2026 proposal, which gives the expected effective date as 18 January 2027.

DateWhat happensWhere it comes from
18 July 2025The Act is approved and becomes Public Law 119-27Public Law 119-27, 139 Stat. 419
18 July 2026Deadline for regulators to issue rules through notice and commentSection 13(a): "Not later than 1 year after the date of enactment"
18 January 2027The Act takes effect at the latestSection 20(1)
18 July 2028Digital asset service providers may no longer offer or sell a payment stablecoin from an issuer that is not permitted, with exceptions in section 3(c) and section 18Section 3(b)(1), "3 years after the date of enactment"

The July 2028 date applies to exchanges and other digital asset service providers: it is when the selling ban in section 3(b)(1) starts. The ban on issuing without a permit in section 3(a) has no delay of its own, so it applies from the effective date.

Have the GENIUS Act rules been finalised?

No final rule from a primary federal payment stablecoin regulator appears in the Federal Register as of 15 October 2026. We searched the Federal Register for "GENIUS Act" and for "payment stablecoin" that day. Section 13(a) set 18 July 2026 as the deadline to issue rules through notice and comment, and no final rule had appeared by then. The main documents, by publication date:

PublishedAgencyDocumentStatus on 15 October 2026
2 March 2026OCCRules for issuers under OCC jurisdictionProposed; comments closed 1 May 2026
3 April 2026TreasuryPrinciples for "substantially similar" state regimesProposed; comments closed 2 June 2026
10 April 2026FDICStandards for FDIC-supervised issuersProposed; comments closed 9 June 2026
10 April 2026FinCEN and OFACIssuer anti-money laundering and sanctions programmesProposed; comments closed 9 June 2026
18 August 2026TreasuryIssuance, offer and sale (section 3)Proposed; comments due 19 October 2026
29 September 2026Federal ReserveThe Board's responsibilities under the ActProposed; comments due 30 November 2026
30 September 2026Treasury, for the Stablecoin Certification Review CommitteeForms and procedures for state certificationsInterim final rule, effective 30 September 2026; comments due 30 November 2026

The same search finds further proposals from the NCUA, FinCEN, the OCC, the FDIC and the Federal Reserve, among them a customer identification programme for issuers, and Treasury's advance notice of proposed rulemaking from September 2025. The one rule in force is procedural: it sets the forms a state regulator uses to certify its regime, and its dates section says certifications will not be accepted until the information collection has Paperwork Reduction Act approval.

What does the GENIUS Act require of stablecoin issuers?

The GENIUS Act requires a permitted issuer to back every outstanding payment stablecoin at least 1 to 1 with a short list of liquid assets, to publish what those reserves are every month, and to pay holders no interest. The obligations sit in section 4(a):

  • Reserves, 4(a)(1)(A). At least 1 to 1, in assets such as US coins and currency, Federal Reserve balances, demand deposits, Treasury bills, notes or bonds with 93 days or less to maturity, certain overnight repurchase agreements, and government money market funds holding those assets, plus other similarly liquid federal government assets a regulator approves.
  • Redemption policy, 4(a)(1)(B). Clear procedures for timely redemption, and all purchase and redemption fees disclosed, changeable only with at least 7 days' notice.
  • Monthly disclosure, 4(a)(1)(C) and 4(a)(3). The reserve make-up published on the issuer's website each month, examined by a registered public accounting firm, and certified by the chief executive and chief financial officer.
  • No yield, 4(a)(11). "No permitted payment stablecoin issuer or foreign payment stablecoin issuer shall pay the holder of any payment stablecoin any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention of such payment stablecoin."
  • Bank Secrecy Act, 4(a)(5)(A). The issuer is treated as a financial institution, and clause (iv) lists "technical capabilities, policies, and procedures to block, freeze, and reject specific or impermissible transactions that violate Federal or State laws, rules, or regulations."

Two more sections concern holders. Section 11(a)(1) gives holders' claims priority over other claims against a permitted issuer in insolvency, with respect to the required reserves. Section 17 amends the Securities Act of 1933, the Securities Exchange Act of 1934, the Commodity Exchange Act and other statutes so that their definitions of a security or a commodity exclude a payment stablecoin issued by a permitted issuer.

Where do businesses that accept stablecoins appear in the GENIUS Act?

Businesses that take stablecoins as payment are not named in the GENIUS Act: the word "merchant" appears once in the enacted text, in the phrase "futures commission merchants" in section 3(g)(2). The prohibitions in section 3 concern issuing a payment stablecoin, and digital asset service providers offering or selling one. The two that set the main rules:

  • Section 3(a): "It shall be unlawful for any person other than a permitted payment stablecoin issuer to issue a payment stablecoin in the United States."
  • Section 3(b)(1): "Except as provided in subsection (c) and section 18, beginning on the date that is 3 years after the date of enactment of this Act, it shall be unlawful for a digital asset service provider to offer or sell a payment stablecoin to a person in the United States, unless the payment stablecoin is issued by a permitted payment stablecoin issuer." That date is 18 July 2028.

A digital asset service provider, in section 2(7)(A), is a person that "for compensation or profit" is in the business in the United States of exchanging digital assets for money or for other digital assets, transferring digital assets to a third party, acting as a digital asset custodian, or taking part in financial services relating to issuance. Section 2(7)(B)(ii) excludes "developing, operating, or engaging in the business of developing distributed ledger protocols or self-custodial software interfaces."

Section 3(h)(1) also exempts three kinds of transaction from section 3. The third, in 3(h)(1)(C), is "any transaction by means of a software or hardware wallet that facilitates an individual's own custody of digital assets." Whether a given business or product falls inside or outside any of these definitions is a legal question we do not answer here.

What does a USDC payment through Fianto involve?

A USDC payment through Fianto is one Solana transaction, signed by the customer's wallet, that sends the price straight to the merchant's own wallet. Fianto is software for that flow: a hosted checkout, a plan for subscriptions, webhooks and a dashboard. It never holds the merchant's money, keeps no balance and makes no payout. When a fee applies, a second transfer in the same transaction sends it to Fianto's treasury. The checkout page says it in one line: "Paid straight to <shop>. Nobody holds it in between." The steps are in how money moves, and what to record for each payment is in accounting for USDC revenue.

Fianto accepts one stablecoin, USDC on Solana. USDC is issued by Circle, whose USDC page says, as of 15 October 2026, that "USDC is a digital dollar backed 100% by highly liquid cash and cash-equivalent assets and is redeemable 1:1 for US dollars." How USDC compares with the alternatives for a business is in stablecoin payments for business, why a subscription is priced in it rather than SOL in why price a subscription in USDC, not SOL, and what the customer signs is on the security page.

We make no statement here about how the GENIUS Act, or any regulator, classifies Fianto, USDC or a business that uses them. Fianto reviews every merchant by hand before it can take a payment: a typed business profile, two-factor sign-in and a signed proof of the receiving wallet. That review is our own policy, not a licence or a legal opinion.

See where a USDC payment goes, transaction by transaction, before you sign up.

Read the guide to accepting USDC

What should a business watch for next?

The next dates to watch are the comment deadlines and the first final rules. Treasury's section 3 proposal closes for comment on 19 October 2026, and the Federal Reserve's proposal and the interim rule close on 30 November 2026. Once any primary federal regulator issues a final rule, it will appear in the Federal Register, the place to check rather than a summary. Section 13(c) also requires each federal banking agency to report the rules it issued to the Senate Banking Committee and the House Financial Services Committee within 180 days after the effective date.

If you take payments in the US and want to know whether your own set-up needs a licence, the federal guidance on money transmission is a separate body of rules, covered in do you need a licence to accept crypto payments. The difference between a provider that holds your money and one that does not is in custodial vs non-custodial crypto payments.

Sources
Questions

Questions about the GENIUS Act.

When does the GENIUS Act go into effect?

On 18 January 2027 at the latest. Section 20 picks the earlier of 18 months after enactment or 120 days after final rules from the primary federal regulators, and as of 15 October 2026 no such final rule exists.

Is the GENIUS Act already law?

Yes. It was approved on 18 July 2025 as Public Law 119-27. Being law and being in effect are different: its rules apply from the effective date.

Does the GENIUS Act ban interest on stablecoins?

Section 4(a)(11) bars permitted and foreign issuers from paying holders interest or yield solely for holding, using or keeping a payment stablecoin. The text addresses issuers.

Does the GENIUS Act mention merchants?

Not as businesses that accept stablecoins. The word appears once, in "futures commission merchants" in section 3(g)(2); the prohibitions in section 3 address issuers and digital asset service providers.

Is this legal advice?

No. It reports what the enacted text and the Federal Register say as of 15 October 2026. Ask a lawyer how they apply to your business.

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Read the law, then the ledger.

Trace a USDC payment from the customer's wallet to yours.

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