On July 18, 2025, the United States signed its first federal law governing payment stablecoins — digital tokens whose value is pegged to an asset such as the dollar. Exactly one year later, the total stablecoin market has reached roughly $320 billion, and banks and payment firms now have a legal path to issue regulated dollar tokens [source: The White House, 2025][source: BIS, 2026]. Yet the phrase "going mainstream" is only half true. The door was opened by law, but the detailed supervisory rules needed to actually walk through it are still in draft.
That is why now is the right moment to look at this subject. The one-year gap — between how fast the market has grown and how slowly the rulebook has been assembled — is a real test of whether stablecoins can truly become "mainstream money." This article walks through, in order, what the GENIUS Act changed, what the law actually requires, how far reality has come one year on, how large the market has grown, and what concerns institutions like the Bank for International Settlements (BIS) raise on the other side of the ledger.
Table of Contents
- The door the GENIUS Act opened — what it changed
- What the law requires — reserves, audits, consumer protection
- Reality one year later — the rules are still a draft
- How big the market got
- The other side — three questions from the BIS
- Conclusion — what to watch
The door the GENIUS Act opened — what it changed
From a state-by-state patchwork to one federal line
Formally titled the Guiding and Establishing National Innovation for U.S. Stablecoins Act, the GENIUS Act is the first federal regulatory framework in the United States for payment stablecoins [source: The White House, 2025]. Before it, U.S. stablecoins sat in a gray zone of state-by-state money-transmitter rules and general securities or commodities law. The Act is an attempt to draw a single federal line across that gray zone.
The practical effect of that gray zone was that a product making the same promise to users could sit under different rules depending on where its issuer was registered, and no single federal rulebook defined what that promise had to be worth. The GENIUS Act — S.1582 of the 119th Congress, signed on July 18, 2025 — replaces that arrangement with one federal definition of a payment stablecoin and one federal answer to the question of who is allowed to stand behind it [source: U.S. Congress, S.1582, 2025]. Almost everything else in the statute follows from that single choice.
Three paths, and who supervises each
Its core move is to make clear "who may issue." To issue a payment stablecoin in the United States, you must now be a "permitted payment stablecoin issuer." The law allows three paths: first, a subsidiary of an insured depository institution (a bank); second, a federally qualified nonbank issuer approved and supervised by the Office of the Comptroller of the Currency (OCC); and third, a state-qualified issuer under an approved state regime [source: OCC, 2026]. In short, issuing a stablecoin has shifted from something almost anyone could do to something only a bank — or an entity under comparable supervision — may do.
These are not three versions of the same license, and the difference between them is mainly a difference of supervisor. The first route runs through an insured depository institution: the issuer is a bank's subsidiary. The second is built for firms that are not banks — a federally qualified nonbank issuer has to be approved by the OCC and is then supervised by it. The third runs through a state regime, and that regime must itself be approved before issuers under it qualify [source: OCC, 2026]. What the three share is the change the statute makes: being an issuer is now something a supervisor grants, not something a company announces.
What "the door is open" does and does not mean
The significance of this change is not merely symbolic. For banks and large payment firms, a stablecoin is no longer an experiment outside regulation but a licensed business they can enter once they meet the conditions supervisors set. That is what it means to say the door is open. But opening the door and completing all the rules on the other side are different things — and that distinction is the heart of this article.
It is worth being precise about what "open" means here. The statute settles the question of permission — who may issue, and on what basic terms. It does not by itself produce a licensed issuer, because the standards supervisors will apply when they examine an applicant, and the procedure by which they will apply them, are set in a separate rulemaking process. Until those rules are final, a bank or a payment firm can read the law and see the path, but it cannot read the full set of conditions it will eventually be measured against. That gap between permission and procedure is what the rest of this article traces.
What the law requires — reserves, audits, consumer protection
One hundred percent reserves, and what counts as one
The conditions the law places on issuers are designed to hold stablecoins to the promise that "one dollar is always one dollar." The most important requirement is 100% reserves. For every unit of stablecoin issued, the issuer must hold high-quality liquid assets one-for-one — cash and insured deposits, short-dated U.S. Treasuries (for example, bills maturing within about 93 days), and certain repurchase agreements. Reserves are held separately and are designed to be protected even if the issuer fails [source: The White House, 2025][source: OCC, 2026].
The asset list is narrow on purpose. Cash, insured deposits, short-dated Treasuries and certain repos are the instruments most likely to be sellable close to face value at short notice, which is exactly what a promise of redemption at par requires. The maturity example written into the framework — bills maturing within about 93 days — points at the same idea: the shorter the maturity, the smaller the gap between what a reserve asset is worth on paper and what it fetches if it has to be sold in a hurry. Holding reserves separately, and structuring them to survive the issuer's failure, answers the other half of the promise: the assets are meant to belong to token holders rather than to the issuer's creditors [source: The White House, 2025][source: OCC, 2026].
Monthly disclosure, examination, and certification
Transparency requirements follow. Issuers must publicly disclose the composition of their reserves every month, and that disclosure is examined by a registered public accounting firm. The chief executive officer (CEO) and chief financial officer (CFO) must certify its accuracy to supervisors [source: The White House, 2025][source: OCC, 2026]. This is a direct answer to past episodes in which some stablecoins claimed to be "fully backed" while disclosing too little about their composition to earn trust.
This is also the point at which two similar-sounding things have to be kept apart. What the statute requires is a monthly public disclosure of reserve composition that a registered public accounting firm examines, with the CEO and CFO certifying its accuracy to regulators [source: The White House, 2025][source: OCC, 2026]. What mostly exists in the market today is attestation — figures issuers publish about their own reserves. Those company-published figures have not been examined under final GENIUS rules, for the simple reason that final rules do not yet exist, so this article treats them as company statements rather than independently verified numbers. The distinction applies to every reserve figure a reader will meet in the meantime.
Consumer safeguards: no yield, no implied backing
Consumer safeguards come in several layers. As financial institutions under the Bank Secrecy Act (BSA), issuers carry know-your-customer (KYC) and anti-money-laundering (AML) obligations, and they must have the technical ability to seize, freeze, or burn tokens when legally required [source: The White House, 2025]. Issuers are also prohibited from paying interest or yield to stablecoin holders. They may not advertise that they are backed by the government or covered by federal deposit insurance [source: The White House, 2025]. And if an issuer goes bankrupt, stablecoin holders' claims take priority over other creditors [source: The White House, 2025].
Two of those provisions deserve a second look, because together they define what a payment stablecoin is allowed to be. The ban on paying interest or yield keeps the instrument on the payments side of the line: a permitted stablecoin is something you hold in order to pay, not something you hold in order to earn [source: The White House, 2025]. The marketing limits do the same work from the other direction — an issuer may not suggest that the government stands behind the token or that federal deposit insurance covers it, which closes off the most convenient way to borrow trust an issuer has not built [source: The White House, 2025]. The seize, freeze and burn requirement, for its part, is a design constraint: the ability to act on a legal order has to be built into the token itself.
Where the statute stops and the rulebook begins
Together these requirements pull stablecoins closer to being a "regulated money-like instrument." But there is one important layer to distinguish here. These provisions are the principles set out in the statute; the detailed rules for how supervisors will examine and enforce each one in practice must go through a separate rulemaking process. And it is exactly those detailed rules that, one year on, remain unfinished.
Reality one year later — the rules are still a draft
The deadline the law set for itself
The law came with a deadline. The GENIUS Act required regulators to issue implementing regulations within one year of enactment — that is, by July 18, 2026 [source: OCC, 2026]. This article is being written just after that deadline. So, are the rules finished?
Proposed, not final: what the agencies published
Here we have to separate announcement from verification. It is true that several federal agencies were active over the past year. On February 25, 2026, the OCC issued Bulletin 2026-3, containing a "GENIUS Act Regulations: Notice of Proposed Rulemaking (NPRM)" [source: OCC, 2026]. The Federal Deposit Insurance Corporation (FDIC) likewise published a notice of proposed rulemaking for the issuers it supervises in the Federal Register on April 10, 2026 [source: FDIC, 2026]. But the precise nature of these documents is "proposed rule" — not a finalized rule, but a draft open for comment.
The activity also involved more than the two agencies most often named. Alongside the OCC and the FDIC, the National Credit Union Administration and the Treasury Department — including FinCEN and OFAC — took part in the year-one rulemaking, with the Federal Reserve involved as well. Counted together, the six issued roughly ten proposed rulemakings over the year, a figure best read as an approximation of the volume of activity rather than an official tally. Several of the comment periods attached to those proposals run past the one-year mark, which means that on the deadline itself some of the drafts had not yet finished collecting the responses a final rule would have to address.
Why "no final rule" is a primary-source judgment
To put it plainly: six federal agencies issued numerous notices of proposed rulemaking over the year, but no agency is confirmed to have finalized its implementing rules by the July 18, 2026 deadline. This judgment rests not on any particular news report but on primary facts — that every published rule is at the proposed stage (OCC Bulletin 2026-3, the FDIC Federal Register notice), that the law set a one-year deadline, and that no final rule has been confirmed as published.
It is worth stating plainly what this article does not rest on. A "they missed the deadline" narrative circulated widely in crypto trade press, and none of those reports are used here. The judgment above is assembled only from documents a reader can check: a bulletin that describes itself as a notice of proposed rulemaking, a Federal Register notice that does the same, and a statutory clause fixing the one-year date [source: OCC, 2026][source: FDIC, 2026]. It would be overturned by exactly one thing — the publication of a final implementing rule — and that single event, rather than another round of headlines, is what a reader should watch for.
The effective date moves with the rulebook
Why does this matter? Because the law's own effective date is tied to it. The GENIUS Act takes effect on the earlier of "18 months after enactment (January 18, 2027)" or "120 days after the primary federal regulators issue final regulations" [source: OCC, 2026]. If final regulations are delayed, the effective date naturally slides toward January 2027. In other words, the law has passed, but a "fully operative rulebook" is still being assembled. Even though stablecoins have entered the mainstream in legal terms, the fine grammar of supervision is still being written.
For anyone waiting to issue, the practical reading is that the calendar now has a floor rather than a schedule. If no final regulation arrives first, January 18, 2027 is when the statute begins to apply on its own terms; if final regulations do arrive, the clock instead runs 120 days from their publication [source: OCC, 2026]. Neither branch is the announcement of a launch date, and neither tells a prospective issuer when its own application would be decided. It tells them only when the law under which such a decision is made becomes operative.
How big the market got
The headline numbers
Even while the rules stayed in draft, the market itself grew quickly. According to the BIS, the total stablecoin market capitalization was about $320 billion at the end of May 2026, and on-chain transaction volume over 2025 reached roughly $28 trillion [source: BIS, 2026]. The numbers alone look overwhelming.
Four kinds of numbers, one market
Because stablecoin figures travel quickly, it helps to sort them by origin before comparing any of them. The market capitalization and the transaction volume above are compilations published by an international institution in its annual report [source: BIS, 2026]. Reserve figures for individual issuers are company statements, published by the issuers themselves. Market-share splits generally originate with commercial data aggregators. And figures such as the $2 trillion discussed at the end of this section are official projections carrying explicit conditions. Those are four different kinds of claim, and ending in "billion" or "trillion" is close to the only thing they have in common.
Why $28 trillion sits next to three business weeks
But the same BIS report urges caution in reading them. Even that $28 trillion in volume amounts to "less than three business weeks" of settlement in the largest U.S. wholesale payment systems [source: BIS, 2026]. In other words, stablecoins have grown fast, but measured against the whole of existing core payment infrastructure they are still a small slice. A large growth rate and a large scale are claims at different layers, and mixing them makes it easy to overstate the case as "money has already been replaced."
The comparison the BIS chooses is deliberate. It sets a year of stablecoin turnover against the settlement volumes of the systems that already move wholesale dollars, and finds the former worth less than three business weeks of the latter [source: BIS, 2026]. That is a statement about level, not about direction. A market can be growing quickly and still be a small share of the whole; both things can be true at the same time, and an argument that quietly swaps one claim for the other has stopped reporting and started persuading.
Concentration, Treasuries, and company-reported data
The market's structure is also worth noting. The stablecoin market is heavily concentrated in a few dollar-pegged issuers, and among them USDT and USDC are the two largest. Precise market-share figures come mainly from market aggregators, so we do not assert a specific number here. Issuers hold large amounts of short-term U.S. Treasuries as reserves, which links the growth of the stablecoin market to the U.S. Treasury market. That said, per-issuer Treasury holdings generally rest on issuers' own attestations and have not yet undergone independent examination under final GENIUS rules. They should therefore be treated as "company statements," and it is too early to treat them as fully verified figures.
This is where the unfinished rulebook has a second effect that is easy to overlook. The statute's monthly disclosure requirement — examined by a registered public accounting firm and certified by the issuer's chief executives — is precisely the mechanism that would convert today's company statements into supervised numbers [source: The White House, 2025][source: OCC, 2026]. Until the implementing rules are final and issuers are operating under them, the most consequential figures in this market, namely how much of which asset sits behind each token, remain reported rather than examined. The link between stablecoin growth and the Treasury market is therefore real in direction while remaining imprecisely measured in public.
A projection is not a measurement
Projections also circulate. In Senate testimony in June 2025, U.S. Treasury Secretary Scott Bessent said the U.S. dollar stablecoin market could exceed $2 trillion by the end of 2028 if the legal framework takes hold, and he framed stablecoins as a new source of demand for U.S. government debt [source: U.S. Treasury/Bessent Senate testimony, 2025]. But this is a conditional official projection, not a measured fact. Such projections can shift widely with the state of the rules, market confidence, and macro conditions, so it is more accurate to read it as one scenario rather than a fixed trajectory.
A conditional projection is still useful, as long as it is read for what it is. The condition attached to this one is the framework taking hold — the same framework this article has just described as unfinished [source: U.S. Treasury/Bessent Senate testimony, 2025]. The framing around it, stablecoins as a new source of demand for U.S. government debt, is an argument about why the outcome would be welcome rather than evidence that it will arrive. Read that way, the figure is a statement of official expectation and a description of an incentive, and it belongs in a different column from anything that has been measured.
The other side — three questions from the BIS
Why the BIS frames it as three tests
There is no room to be purely optimistic about stablecoins entering the mainstream. In its 2026 Annual Economic Report, the BIS judged that stablecoins do not sufficiently meet the three conditions of "sound money" [source: BIS, 2026]. This critique must be presented alongside the upside for the sake of a multi-perspective account.
The three tests: singleness, elasticity, integrity
The first is singleness. Sound money should always exchange at the same face value regardless of who issues it. But the BIS points out that stablecoins cannot guarantee par exchange across issuers and blockchains under all conditions, and that secondary-market prices sometimes deviate from par or redemption frictions arise.
The second is elasticity. Stablecoins are bound to a "cash-in-advance" model in which reserve assets must be secured before issuance, so supply is constrained by the liquidity and depth of those reserve assets.
The third is integrity. The BIS finds that stablecoins account for a significant share of illicit on-chain activity, and that pseudonymity makes anti-money-laundering and counter-terrorist-financing efforts harder [source: BIS, 2026].
Taken together, the three tests ask a single question in three ways: can this instrument be relied on as money by people who never chose it? Exchange at par is what allows a payment to be accepted without inspecting who issued the token. Elasticity is what allows supply to meet demand without a queue. Integrity is what keeps the system usable by institutions bound by anti-money-laundering duties. The BIS does not say stablecoins fail these tests forever; it says they do not currently meet them well enough to carry the role of money on their own [source: BIS, 2026].
Run risk, disintermediation, dollarisation
There are macro risks as well. The BIS warns that in a large redemption event (a run), an issuer's fire sales of reserve assets could transmit the shock into short-term funding markets. It also notes that if stablecoins are used widely, deposits could flow out of banks (disintermediation), pressuring banks to raise deposit rates or change their asset mix. In emerging and developing economies, rising demand for dollar stablecoins could produce "stablecoin dollarisation" that sharply curtails the autonomy of domestic monetary policy [source: BIS, 2026].
The mechanism behind the run warning is worth stating slowly, because it is the reason a payments question turns into a financial-stability question. Reserves are held in short-term instruments; a wave of redemptions forces those instruments to be sold quickly; and selling them quickly moves the price of exactly the assets other institutions rely on for short-term funding [source: BIS, 2026]. The disintermediation channel works through balance sheets rather than prices — deposits leaving banks would push banks to compete harder for funding or to hold more liquid assets. And in emerging and developing economies the BIS puts the issue in terms of sovereignty: heavy demand for foreign stablecoins would not merely change what people pay with, it would erode the monetary sovereignty a central bank needs to act [source: BIS, 2026].
What the BIS conclusion says
The BIS's conclusion is cautious. Stablecoins in their current form cannot replace the two-tier monetary system of central-bank and commercial-bank money, and the associated risks require internationally coordinated safeguards [source: BIS, 2026]. In short, the fact that stablecoins have passed through the legal door does not automatically settle the question of their trustworthiness as money.
That conclusion is narrower than the public argument usually allows. What the BIS states is that stablecoins in their present form cannot substitute for the two-tier arrangement of central-bank and commercial-bank money, and that the risks involved call for safeguards coordinated across borders [source: BIS, 2026]. The remedy it names is coordination rather than prohibition, which follows from the shape of the risks: reserves, redemption and illicit-use problems do not stop at the border of whichever jurisdiction licensed the issuer.
Conclusion — what to watch
The one-year scorecard
The one-year report card on the GENIUS Act is hard to sum up in a single line. The law drew a federal line around stablecoins, opened a clear entry path for banks and payment firms, and the market has grown to about $320 billion [source: BIS, 2026]. Yet the detailed rules that would actually support that path remain in draft, and the law's own one-year deadline passed without final rules. "Going mainstream" is already happening in law and in the market, but in the fine grammar of supervision it is still in progress.
Four things to watch
So the points to watch are clear. First, when the six agencies' notices of proposed rulemaking are finalized — this governs when the law actually takes effect. Second, whether the first bank and payment-firm issuers actually obtain licenses and enter the market. Third, whether the reserve framework actually holds up under stress such as fire sales and runs. Fourth, whether dollarisation pressure and bank disintermediation in emerging economies show up in the data. These four will decide, over the coming quarters, whether "going mainstream" stays a slogan or becomes a working reality. What is needed now is not a verdict but the discipline to watch the rules, the market, and the risks together, at the same eye level.
There is a common thread running through all four. Each one converts something currently announced into something eventually checkable: a proposed rule becomes a published final rule, an intention to issue becomes a granted license, a reserve claim becomes an examined disclosure, and a warning about dollarisation becomes a series in the data. That conversion is the entire difference between a market that is talked about and a market that can be verified. One year in, the GENIUS Act has moved stablecoins a long way down the first road and has only started on the second.