Stablecoin licensing: frequently asked questions
Short answers to the questions issuers, banks and fintechs ask most about the GENIUS Act.
When do stablecoin issuers need a license in the US?
The GENIUS Act takes effect on the earlier of January 18, 2027 (18 months after enactment) or 120 days after final implementing regulations are issued. From then on, only permitted payment stablecoin issuers may issue payment stablecoins in the US.
Which regulator approves a stablecoin issuer?
Bank subsidiaries are approved by their primary federal regulator, nonbank "federal qualified issuers" by the OCC, and "state qualified issuers" by their state regulator. See the pathway comparison.
How long does approval take?
Regulators must decide within 120 days after informing the applicant that its application is complete. Getting to a complete application usually takes longer, so starting early matters.
What is the $10 billion threshold?
A state qualified issuer whose consolidated outstanding issuance exceeds $10 billion must transition to federal oversight within 360 days, unless it obtains a waiver.
Can a licensed stablecoin pay interest or yield?
No. Permitted payment stablecoin issuers may not pay interest or yield to holders.
What assets can back a payment stablecoin?
At least one-to-one reserves in eligible assets: US currency, insured deposits, Treasury bills, notes or bonds maturing in 93 days or less, qualifying repurchase agreements and government money market funds, among others permitted by regulators.
What reporting is required?
A monthly public report on reserve composition, examined by a registered public accounting firm and certified by the CEO and CFO. Issuers above $50 billion outstanding must also publish audited annual financial statements.
Can foreign stablecoin issuers operate in the US?
Yes, if Treasury determines their home regime is comparable and they meet additional conditions (including OCC registration and holding sufficient reserves in US institutions). From July 18, 2028, service providers may not offer non-permitted payment stablecoins to US persons.
What are the penalties for issuing without a license?
Knowingly issuing a payment stablecoin in the US without approval can be punished by fines of up to $1,000,000 per violation, up to five years' imprisonment, or both.
Is this website affiliated with a regulator?
No. StablecoinLicensing.com is an independent information resource. It is not affiliated with Treasury, the OCC or any government agency, and it does not provide legal advice.
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