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What the GENIUS Act 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.

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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.

Where reporting practice goes from here

Citations

  1. GENIUS Act, S. 1582 (119th Congress), enrolled text — section 20, the effective date
  2. Treasury, GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale — FR Doc 2026-16796

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Questions

Common 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.

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