Stablecoin Regulation Tracker
Structured breakdowns of the GENIUS Act, OCC rulemaking, and PPSI applications. Every requirement, deadline, and applicant in one place.
Educational resource, not legal advice. Verify all requirements with qualified counsel.
Regulatory Timeline
Key dates and milestones for stablecoin regulation
MiCA ART/EMT Regime Takes Effect
EU framework for asset-referenced tokens and e-money tokens becomes enforceable.
MiCA CASP Regime Takes Effect
Full Crypto-Asset Service Provider licensing requirements enforced across EU.
MAS Stablecoin Framework Finalized
Monetary Authority of Singapore finalizes single-currency stablecoin regulatory framework under the Payment Services Act.
GENIUS Act Signed Into Law
First federal framework for payment stablecoins. Establishes PPSI licensing, 1:1 reserve requirements, monthly attestation, and BSA/AML obligations.
OCC Publishes Proposed Rulemaking
Draft implementation rules for PPSI applications, reserve management, governance structures, and risk controls. Comment period opens.
OCC Comment Period Closes
Deadline for public comments on proposed PPSI rules per the Federal Register notice. A separate rulemaking for BSA/AML and OFAC provisions is expected.
Final Rules Published
OCC, FDIC, and Federal Reserve expected to publish final implementing regulations. No official date has been committed.
UK FCA Stablecoin Rules Published
Financial Conduct Authority expected to finalize its stablecoin regulatory framework under the Financial Services and Markets Act 2023.
GENIUS Act Effective Date
Effective the earlier of 18 months after enactment (January 18, 2027) or 120 days after final implementing rules are issued. All issuers must comply. State-qualified issuers with <$10B can operate under state regimes.
GENIUS Act Requirements Matrix
Specific obligations by category, section, and applicability
| Category | Requirement | Section | Applies To | Status |
|---|---|---|---|---|
| Reserves | Maintain 1:1 reserve backing with eligible high-quality liquid assets at all times | § 4(a)(1) | All Issuers | Enacted |
| Reserves | Eligible reserve assets: US currency, Treasury bills/notes/bonds (≤93 days remaining maturity), repurchase and reverse repurchase agreements (fully collateralized by Treasuries), FDIC-insured demand deposits, insured credit-union deposits, central bank reserves, government money market funds, and tokenized forms of the foregoing | § 4(a)(2) | All Issuers | Enacted |
| Reserves | Reserves must be held separate from issuer operating funds; not available for lending, rehypothecation, or pledging | § 4(a)(3) | All Issuers | Enacted |
| Audit | Issuer must publish monthly reserve disclosures within 30 days of period end, with CEO/CFO certification. Month-end report examined by a registered public accounting firm. | § 4(b)(1) | All Issuers | Enacted |
| Audit | Monthly public disclosure of reserve composition by asset class, total stablecoin outstanding, reserve ratio, and geographic location of custody | § 4(b)(2) | All Issuers | Enacted |
| Audit | Annual audited financial statements conforming to GAAP, filed with primary regulator (applies to issuers with >$50B outstanding not already subject to Exchange Act reporting) | § 4(b)(3) | >$50B Issuers | Enacted |
| BSA/AML | Full Bank Secrecy Act compliance: KYC, transaction monitoring, suspicious activity reporting (SARs), currency transaction reports (CTRs) | § 5(a) | All Issuers | Enacted |
| BSA/AML | OFAC sanctions screening on all transactions; ability to freeze or block wallets on designated lists | § 5(b) | All Issuers | Enacted |
| Governance | Board of directors requirements, audit and internal control standards, board-level oversight of IT/security programs | § 6(a) | Nonbank PPSI | Proposed |
| Governance | Capital adequacy requirements set by OCC; minimum capital ratios to be determined in final rulemaking | § 6(b) | Nonbank PPSI | Proposed |
| Consumer Protection | Redemption at par value ($1.00 per stablecoin) with clearly disclosed procedures for timely redemption | § 7(a) | All Issuers | Enacted |
| Consumer Protection | Clear, prominent disclosures: stablecoin is not FDIC-insured, not a bank deposit, may lose value in insolvency | § 7(b) | All Issuers | Enacted |
| Reporting | Quarterly reports to primary regulator: stablecoin outstanding, reserve composition changes, material risk events, redemption volumes | § 8(a) | All Issuers | Proposed |
OCC Rulemaking Tracker
Status of proposed rules implementing the GENIUS Act
Key Provisions in Proposed Rulemaking
Who's Applying for PPSI Status
Companies that have filed or are expected to file for OCC national trust bank charters or PPSI applications. Statuses are based on public reporting and may not reflect the latest developments.
BitGo
FiledDigital asset custody and infrastructure
Crypto.com
ReportedCrypto exchange seeking national trust bank charter
Fidelity Digital Assets
ReportedTradFi custody arm exploring stablecoin issuance
Paxos
FiledExisting issuer (PYUSD custodian, former BUSD issuer)
Protego Trust
FiledConditionally approved national trust bank
Ripple
FiledRLUSD stablecoin issuer
Western Union
ReportedRemittance giant entering stablecoin issuance
PPSI Application Guide
Step-by-step process for becoming a Permitted Payment Stablecoin Issuer
Determine Your Path: Federal vs State
Issuers with <$10B outstanding can operate under state regimes. Above $10B requires federal OCC charter, though the act provides transition periods and extension paths for state-qualified issuers that cross the threshold.
Prepare Application Materials
Business plan, 3-year financial projections, governance structure, compliance program design, technology architecture, cybersecurity framework, and key personnel backgrounds.
Submit Pre-Filing Meeting Request
Schedule confidential meeting with OCC Licensing Division. Required before formal application. Discuss business model, regulatory expectations, and application readiness.
File Formal Application
Submit charter application via the OCC interagency application process with all required exhibits and supporting documents. Filing fees vary; check the OCC Licensing Manual for current requirements.
OCC Review Period
OCC conducts background checks, financial analysis, business plan review, and on-site assessments. May issue supplemental information requests. Public comment period on application (30 days).
Conditional Approval
If approved, OCC issues conditional charter with specific requirements to fulfill before commencing operations (capital funding, system testing, compliance validation).
Commence Operations
After satisfying all conditions, issuer begins stablecoin operations under ongoing OCC supervision, examination, and reporting requirements.
Federal vs State: Which Path?
Side-by-side comparison of federal OCC charter vs state-level stablecoin frameworks
| Dimension | Federal (OCC) | State Regime |
|---|---|---|
| Eligible issuers | Any size | <$10B outstanding |
| Regulator | OCC (primary) | State banking department |
| Geographic scope | All 50 states | Issuing state + reciprocity |
| State MTL needed? | No (preempted) | Varies by state |
| Capital requirement | TBD (final rules) | State-specific |
| Examination | OCC examiners | State examiners |
| Application timeline | 12-18 months | 6-12 months |
| Est. annual cost | $3-5M/yr | $1-3M/yr |
| Best for | Large issuers, nationwide ops | Smaller issuers, regional ops |
Frequently Asked Questions
What is the GENIUS Act?
What is a Permitted Payment Stablecoin Issuer (PPSI)?
When does the GENIUS Act take effect?
Can stablecoin issuers pay interest or yield to holders under the GENIUS Act?
How does the GENIUS Act compare to MiCA?
Related Guides
GENIUS Act Explainer
Plain-language breakdown of the first US federal stablecoin law
Is USDC Safe?
How USDC reserves, audits, and regulation protect your money
USDC Tax Guide
Tax implications of holding, earning, and transacting with USDC
Glossary
Definitions of PPSI, HQLA, MiCA, and 80+ more stablecoin terms
This page is for educational purposes only and does not constitute legal or financial advice. Regulatory information is compiled from public sources and may not reflect the most recent developments. USDC.org is an independent educational resource and is not affiliated with Circle Internet Financial, the OCC, or any regulatory body. Consult a qualified attorney for advice on regulatory compliance.
Last updated: March 2026. Content is generated with AI assistance and reviewed by the editorial team before publishing.