GENIUS Act · state money transmission · OCC · FinCEN · state regulators
United States
A federal stablecoin regime with recurring statutory reporting, on top of the most fragmented state licensing map in the world.
Verified
These claims have been checked against the instrument or the regulator's own material. Where a position is unsettled or a rule is still in draft, the page says so rather than implying certainty.
- Effective date is the earlier of 18 Jan 2027 or 120 days after final rules
- Final implementing rules had not been issued as at August 2026 — packages remain proposals
- Broker basis reporting applies from 1 Jan 2026, to covered assets only (acquired after 2025 and held in the same custodial account)
JudgementThe observation that market-structure questions beyond stablecoins remain unresolved is our reading of an unsettled position, not a statement of law.
Why this matters now
The federal stablecoin regime takes effect on the earlier of 18 January 2027 or 120 days after final rules are issued — and the final rules do not yet exist. Regulators passed the statutory rulemaking deadline with the principal packages from the OCC, FDIC, NCUA and Treasury still at proposal stage, so the detail of what monthly reserve reporting actually requires is not yet settled. Build for the obligation, but do not treat any published description of the mechanics as final. Separately, broker basis reporting began in January 2026, the state money-transmitter layer has not gone away, and market-structure questions beyond stablecoins remain genuinely unresolved.
Who is in scope
Whether this reaches you.
- Stablecoin issuers and prospective issuers
- Custodial brokers with reporting obligations
- Firms operating across multiple state licensing regimes
Obligations
What the regime actually requires.
Reserve reporting
Monthly composition reporting on a statutory cadence, examined by a registered public accounting firm, with officer certification. The statute sets the shape; the implementing rules that set the detail are still proposals.
Broker reporting
Basis reporting applies to transactions effected on or after 1 January 2026, but only for covered assets — acquired after 2025, in that broker's custodial account, and held there until disposal. Anything transferred in is noncovered, which is where basis mismatches and the notices that follow them come from.
State licensing
Money transmitter requirements vary by state and have not been displaced.
AML and sanctions
FinCEN and OFAC programme obligations.
Dates
When.
| Date | Event |
|---|---|
| Broker basis reporting begins — covered assets only | |
| GENIUS Act takes effect — the earlier of this date or 120 days after final rules | |
| CARF exchanges begin |
What we do
How we help here.
- Reserve reporting readiness and controls design
- Examination preparation and liaison
- Basis reporting reconciliation
- State licensing mapping
Sources
- 01GENIUS Act (Public Law) and agency rulemaking
Statute settled; OCC, FDIC, NCUA and Treasury rule packages remained proposals as at August 2026 - 02IRS broker reporting regulations
Basis reporting scope and timing
Does United States bind you?
Tell us where you are established, where your customers are and what you hold. That is usually enough to answer it — and to say what is already late.