Treasury's GENIUS Act proposal is a Section 3 NPRM, not the full stablecoin rulebook

The US Treasury has issued a notice of proposed rulemaking, an NPRM, implementing Section 3 of the GENIUS Act. The instrument matters, because it determines what you have to respond to and by when. This is a proposed rule at the comment stage, not a final rule, and it is not the entire stablecoin rulebook. Section 3 is the prohibition provision: who may issue, offer or sell a payment stablecoin in the United States. CoinDesk and The Block covered the release.

The rest of the regime, capital treatment, examination, the detailed supervisory machinery, comes in later rulemakings. Firms that treat this document as the finished rulebook will file comments on the wrong things.

Three dates, and they are the whole story

Comments close 60 days after publication in the Federal Register, which on CoinDesk's readout lands in mid-October 2026. The 60 days run from Federal Register publication, not from the Treasury press release, so the two dates are not the same and the countdown starts on the later one. The exact deadline is the one printed on the docket.

18 January 2027: the statutory bar on unlicensed issuance into the US takes effect. After that date, issuing a payment stablecoin in the United States without being a permitted issuer is unlawful.

18 July 2028: the later bar reaching digital-asset service providers, the exchanges, wallets and platforms that offer or sell these tokens.

That is an 18-month gap between the two prohibitions, and it is the most useful thing on the calendar. Issuers get caught first. The venues that list them get roughly a year and a half of additional runway, and they inherit the harder compliance question, because by July 2028 a platform is responsible for what it lists.

The foreign-issuer problem, and Tether

The provision with the sharpest teeth concerns tokens issued from outside the US. Under the proposal, platforms generally cannot list a foreign-issued stablecoin unless the issuer is capable of complying with lawful orders, such as a seizure or freeze directive, or is covered by a reciprocal arrangement with its home jurisdiction.

This is a technical-capability and jurisdiction test rather than a registration formality. An issuer that cannot demonstrate it is able to act on a US lawful order fails it regardless of its reserves or its market position.

The name the industry is watching is Tether, the largest stablecoin issuer and one domiciled outside the United States. Nothing in the proposal names any company, and this is a live question rather than a determination: whether the largest dollar-denominated stablecoin in circulation can satisfy the lawful-order and reciprocity conditions well before US venues face their July 2028 deadline. That question, not the reserve rules, will decide how US stablecoin liquidity is structured at the end of this.

Reserves

The reserve standard is 1:1 backing in eligible assets: cash, bank deposits and short-term Treasuries. For issuers already running a conservative book, this is close to current practice. For anyone holding commercial paper, corporate credit, secured loans or crypto collateral against outstanding tokens, it is a portfolio migration with a deadline attached, and the deadline is January 2027.

The operative text is the NPRM as published in the Federal Register, with the docket and the comment mechanism on regulations.gov and the announcement among Treasury's press releases. Where a news readout and the Federal Register text disagree, the Federal Register governs.

The takeaway

If you issue a payment stablecoin into the US, or you run a venue that lists one, two dates go on the calendar today: the comment deadline roughly 60 days after Federal Register publication, and 18 January 2027. File a comment before the first if the foreign-issuer capability test or the eligible-asset definition affects your book, because the comment period is the last point at which the text can move. Then work backwards from January 2027 on reserve composition, and from 18 July 2028 on listing eligibility. If you hold anything other than cash, deposits or short-term Treasuries against outstanding tokens, that migration is the long pole and it starts now.