What the GENIUS Act actually requires of stablecoin reserve reporting
The GENIUS Act, enacted in July 2025, requires each permitted payment stablecoin issuer to hold reserves backing outstanding tokens at least one-to-one in narrowly defined assets and to publish a monthly reserve disclosure — composition plus outstanding count — examined by a registered public accounting firm and accompanied by executive certification of the report.
The GENIUS Act — the Guiding and Establishing National Innovation for U.S.
Stablecoins Act, enacted July 2025 — is the first United States federal
licensing regime for payment stablecoin issuers. This explainer covers the
reserve and disclosure mechanics in plain language. The statute's own text
controls in every case: cite
S. 1582, 119th Congress
rather than this summary, and see the glossary for each term
of art.
The reserve requirement
A permitted issuer must
hold reserves backing its outstanding payment stablecoins on at least a
one-to-one basis, composed of
permitted reserve assets: United
States coins and currency, certain insured deposits, short-dated Treasury
bills, certain Treasury-backed repurchase and reverse repurchase
agreements, and certain government money market funds. Reserves must not
be pledged or reused except as the Act allows.
The monthly disclosure
The Act's monthly reserve disclosure
requirement is the part ReserveBeat reads every month: each permitted
issuer publishes the composition of its reserves and the number of its
outstanding payment stablecoins, examined by a
registered public accounting firm,
with executive certification of the report. Those published reports are the
primary sources behind every composition figure on the
coverage board — rendered verbatim at their stated scope, never
recomputed.
What a monthly examination is — and is not — is
covered in the glossary's attestation entries: it is an attestation
engagement over management's assertions, distinct from an
audit.
Redemption, yield, and marketing lines
Three further duties round out the holder-facing mechanics:
A publicly disclosed redemption policy,
including timely redemption procedures and any fees.
A yield prohibition: no interest or yield
to holders solely in connection with holding the stablecoin.
Marketing restrictions: a payment
stablecoin may not be presented as legal tender, as issued or backed by
the United States government, or as federally insured.
Federal and state paths
Supervision runs on
two paths: a federal path under the
relevant federal banking regulator, and a state path for issuers below a
statutory issuance threshold under a state regime the Act deems
sufficiently similar. Which path an issuer takes changes its supervisor,
not its reserve and disclosure duties.
When the Act takes effect (updated 2026-09-25)
Section 20 of the Act makes it effective on the earlier of two dates: 18
months after enactment, or 120 days after the primary federal payment
stablecoin regulators issue final implementing regulations[1].
Treasury's proposed rule on payment stablecoin issuance, offer and sale,
published on August 18, 2026, states that the effective date "is expected to
be January 18, 2027"[2]. On September 25, 2026 the implementing
rules and the reporting forms were still proposals. The dated status of each
is in the GENIUS Act clock.
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Last updated: Timestamps reflect the underlying data — when a figure was captured or a report was published — never when a page was built.
Frequently asked questions
Who may issue a payment stablecoin under the GENIUS Act?
▾
Only permitted payment stablecoin issuers: subsidiaries of insured depository institutions, federally qualified nonbank issuers, and state-qualified issuers, each approved and supervised by the corresponding federal or state regulator. Issuing outside this category is restricted under the Act.
What must the monthly disclosure contain?
▾
The composition of the issuer's reserves and the number of its outstanding payment stablecoins, examined by a registered public accounting firm, with executive certification of the report. The statute states the exact requirements; issuers' published reports show how they meet them in practice.
Is a monthly examined disclosure the same as an audit?
▾
No. An examination is an attestation engagement over management's assertions at a point in time; a financial-statement audit is a different, broader engagement. The glossary covers the engagement types in plain language, with citations to the standard-setters.