The GENIUS Act was enacted in July 2025. This post records when it takes effect and where the rules that implement it stood on September 25, 2026. Every date comes from the statute's enrolled text or from a Federal Register document, and each is linked. This is a dated record, not legal advice. The documents themselves control.
What the statute says
Section 20 of the Act sets the effective date. Its text, quoted verbatim[1]:
SEC. 20. EFFECTIVE DATE.
This Act, and the amendments made by this Act, shall take effect on the earlier of
(1) the date that is 18 months after the date of enactment of this Act; or
(2) the date that is 120 days after the date on which the primary Federal payment stablecoin regulators issue any final regulations implementing this Act.
What Treasury says the date is
Treasury's proposed rule on payment stablecoin issuance, offer and sale was published on August 18, 2026, with comments closing on October 19, 2026[2]. It states:
The effective date of the GENIUS Act is expected to be January 18, 2027 (i.e., the date that is 18 months after the date of enactment of the GENIUS Act).
The second path in section 20 is 120 days after final implementing regulations. For that path to come first, final regulations would have had to issue by September 20, 2026, which is 120 days before January 18, 2027. A Federal Register search on September 25, 2026 found no final rule implementing the Act[5].
Where the implementing proposals stand
The table lists the proposals that set issuer requirements, plus the reporting-form and licensing notices, as the Federal Register showed them on September 25, 2026.
| Document | Agency | FR Doc | Published | Comments closed or close |
|---|---|---|---|---|
| Implementing rule, OCC-jurisdiction issuers | OCC | 2026-04089 | 2026-03-02 | 2026-05-01 |
| State-regime "substantially similar" principles | Treasury | 2026-06489 | 2026-04-03 | 2026-06-02 |
| Implementing rule, FDIC-supervised issuers | FDIC | 2026-06974 | 2026-04-10 | 2026-06-09 |
| Implementing rule, NCUA-jurisdiction issuers | NCUA | 2026-09915 | 2026-05-18 | 2026-07-17 |
| Reporting forms, OCC-jurisdiction issuers | OCC | 2026-11856 | 2026-06-12 | 2026-08-11 |
| Reporting forms, FDIC-supervised issuers | FDIC | 2026-14589 | 2026-07-20 | 2026-09-18 |
| Licensing and registration applications | Treasury and OCC | 2026-15088 | 2026-07-27 | 2026-09-25 |
| Issuance, offer and sale (section 3) | Treasury | 2026-16796 | 2026-08-18 | 2026-10-19 |
Every row is still a proposal or a proposed information collection: the search found no final version of any of them.
The reporting forms
Two of the rows are the forms an issuer would use to report to its regulator. The OCC's proposed forms[3] opened for comment on June 12, 2026, and the comment period closed on August 11, 2026. That notice said a second notice, with a 30-day comment period, would follow. The September 25, 2026 search found no second notice. The FDIC's proposed forms[4] were published on July 20, 2026, and their comment period closed on September 18, 2026.
The licensing and registration notice is an information-collection notice for the application itself. Its comment period closes on September 25, 2026.
What this means for the reports ReserveBeat reads
The tracked issuers already publish monthly or quarterly reserve reports, and those published reports are what the coverage board reads today. The glossary entry on the monthly reserve disclosure covers what the Act asks those reports to contain. The board states what each report says at its stated scope. It does not say whether an issuer meets the Act.