The GENIUS Act’s Own Deadline Passed in July. The OCC Now…

The Office of the Comptroller of the Currency expects to finalize its main GENIUS Act regulations by November, four months after a statutory deadline Congress established for regulators to complete the U.S. stablecoin rulebook.Comptroller Jonathan Gould gave the updated timeline during the Wyoming Blockchain Symposium on August 19. "We will have a final rule out by November," Gould said, adding that the agency had begun working on its regulations before President Donald Trump signed the legislation.The Guiding and Establishing National Innovation for U.S. Stablecoins Act became law on July 18, 2025. Section 13 gave primary federal payment stablecoin regulators, Treasury and state stablecoin regulators no more than one year to promulgate implementing regulations through notice-and-comment rulemaking. That made July 18, 2026 the statutory deadline. It passed without the principal implementing rules becoming final.

July 18 Was a Statutory Deadline

The missed date was not merely an agency target. The OCC's own federal regulatory agenda identifies July 18, 2026 as the statutory final-rule deadline for its GENIUS Act implementation. The agency had moved considerably ahead of that date.On February 25, it proposed a broad framework covering reserve assets, redemption requirements, risk management, audits, custody, supervision, applications, capital requirements and treatment of foreign stablecoin issuers. The proposal appeared in the Federal Register on March 2.Separate anti-money-laundering, counter-terrorist-financing and sanctions requirements were proposed through coordinated rulemaking in June. But proposed rules are not final compliance standards. Industry comments can still change requirements involving capital, liquidity, reserve management, reporting and supervisory procedures before publication.The statute does not specify an automatic penalty, substitute regulation or extension mechanism when regulators miss Section 13's deadline. The agencies therefore continue writing the rules despite having passed the date Congress prescribed.

November Does Not Replace the Deadline

Gould's November commitment should consequently be understood as the OCC's new administrative target rather than an amended GENIUS Act deadline. The timing also interacts with a separate provision governing when the legislation becomes effective.The GENIUS Act takes effect on the earlier of two dates: 18 months after enactment, or 120 days after the primary federal stablecoin regulators issue final implementing regulations. Eighteen months after July 18, 2025 is January 18, 2027.That means an OCC final rule published in November would not necessarily move implementation into March simply because 120 days would extend beyond January. The statute uses the earlier date. Unless the relevant final-rule trigger occurs sufficiently early to produce an earlier effective date, January 18 remains the outside statutory start date.That distinction leaves the industry facing a compressed preparation period. The OCC's proposed framework reaches across virtually the entire stablecoin lifecycle, from eligible reserves and redemption to custody, examinations and issuer applications. It also matters internationally.The GENIUS Act establishes a pathway for foreign payment stablecoin issuers, subject to requirements including comparable foreign regulation and U.S. supervisory conditions. Details of that system remain dependent on implementing regulations and Treasury determinations. The delay therefore does not mean the GENIUS Act has disappeared or that its requirements have been postponed automatically.Congress established the framework in statute, and agencies have produced extensive proposals beneath it. What remains unfinished are the detailed regulations companies will actually use to structure compliance. The OCC now says those rules will arrive by November. If it meets that target, the agency will have completed one of the most important pieces of the U.S. stablecoin framework — but roughly four months after the deadline written into the law itself.