# What the GENIUS Act actually requires of stablecoin reserve reporting
A plain-language explainer of the GENIUS Act's reserve and disclosure requirements for permitted payment stablecoin issuers: one-to-one reserves in permitted assets, monthly examined disclosures, executive certification, and the marketing lines an issuer may not cross.
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](https://www.congress.gov/bill/119th-congress/senate-bill/1582)
rather than this summary, and see the [glossary](/learn) for each term
of art.
Most coverage of the Act has stayed on the licensing horse race — who
may issue, under which regulator, on what timeline. Practitioners should
read the disclosure mechanics first, because that is the part that
produces a public, recurring document trail. Licensing decides who sits
at the table once; the monthly disclosure decides what anyone can check,
every month, for as long as the token circulates. It is also the part
you can act on today: the reports the Act requires are ordinary
published documents, and reading them well is a skill the licensing
headlines never exercise.
## The reserve requirement
A [permitted issuer](/learn/permitted-payment-stablecoin-issuer) must
hold reserves backing its outstanding payment stablecoins on at least a
one-to-one basis, composed of
[permitted reserve assets](/learn/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](/learn/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](/learn/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](/learn/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](/learn/audit).
Read plainly, a monthly examined disclosure tells a holder this much: at
a stated date, management asserted a reserve composition and an
outstanding token count, and a registered public accounting firm
examined those assertions under attestation standards. That is a real
floor, and a higher one than the pre-Act status quo. What it does not
tell a holder: anything about the days between report dates; anything an
examination's scope does not reach (it is a point-in-time attestation
engagement, not an audit); and anything the issuer chose not to itemize
within the rules — depth of itemization, publication lag, and per-chain
detail all still vary from report to report. That is a statement about
what the engagement type can carry, not about any particular issuer.
## Redemption, yield, and marketing lines
Three further duties round out the holder-facing mechanics:
- A publicly disclosed [redemption policy](/learn/redemption-policy),
including timely redemption procedures and any fees.
- A [yield prohibition](/learn/yield-prohibition): no interest or yield
to holders solely in connection with holding the stablecoin.
- [Marketing restrictions](/learn/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](/learn/state-federal-issuer-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.
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". 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](/research/when-does-the-genius-act-take-effect).
## Where reporting practice goes from here
My expectation — opinion, clearly labeled as such — is that reporting
practice converges upward from the statutory floor. Once a few permitted
issuers publish promptly-issued, deeply itemized monthly reports, sparse
disclosure starts to read as a choice rather than a norm, and choices
invite questions. Watch three things as the Act's deadlines arrive:
publication lag shrinking, itemization deepening toward instrument-level
detail, and per-chain circulation breakdowns moving from rare to
expected. The statute fixes the minimum; the interesting movement will
happen above it, and it will be visible one published report at a time.
## Disclaimer
ReserveBeat renders figures from issuer-published reports and public blockchains, verbatim and at their stated scope. It is not an auditor, makes no attestation, and states no opinion on any issuer's solvency. Nothing here is investment, trading, legal, tax, or accounting advice. No figure published here is a recommendation to hold, buy, sell, or redeem any token.
Tracked tokens are subjects of public data: supply figures are read from their public Ethereum contracts, and composition figures from the issuers' own published attestation reports. No tracked issuer is a customer and none has endorsed this site.
Source: https://reservebeat.com/research/genius-act-attestation-requirements