# When does the GENIUS Act take effect? January 18, 2027, and what is still proposed

The GENIUS Act's effective-date clock: the statute's two dates, Treasury's stated expectation of January 18, 2027, and a dated status table of the implementing proposals and reporting forms as found in the Federal Register on September 25, 2026.

The [GENIUS Act](/research/genius-act-attestation-requirements) 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<Cite n={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<Cite n={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<Cite n={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<Cite n={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<Cite n={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](/learn/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.

## 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/when-does-the-genius-act-take-effect