How to get a stablecoin license in the US

1. Confirm you are issuing a "payment stablecoin"

The GENIUS Act targets digital assets designed to be used for payment or settlement, which the issuer is obligated to redeem for a fixed amount of money and represents will maintain a stable value. If your token fits this definition and will be issued in the United States, you need approval as a permitted payment stablecoin issuer once the Act takes effect.

Tokens that don't meet the definition (for example, certain deposit tokens or yield-bearing products) may fall under other regimes. The boundary matters, so get this analysis right before anything else.

2. Choose your licensing pathway

There are three domestic routes. Your existing structure usually points to one of them:

• Subsidiary of an insured depository institution: for banks and credit unions. Approval comes from the parent's primary federal regulator.
• Federal qualified issuer: for nonbank entities, uninsured national banks and federal branches. Approval comes from the OCC.
• State qualified issuer: for US-formed entities under a state regime that is "substantially similar" to the federal framework. Once consolidated outstanding issuance exceeds $10 billion, the issuer must transition to federal oversight within 360 days, unless a waiver is granted.

The state route can offer a faster start for smaller issuers. The federal route offers one nationwide license. Growth plans, capital and existing licenses (money transmitter, trust charter, etc.) all weigh on the choice.

3. Build the application

Final application content will depend on each regulator's implementing rules. Based on the statute and proposed rules, expect to document:

• Business plan: target markets, distribution partners, projected issuance, revenue model (remember: no yield to holders).
• Reserve management: 1:1 backing with eligible assets (cash, insured deposits, Treasuries maturing in 93 days or less, qualifying repos, government money market funds), custody arrangements and segregation.
• Redemption policy: how and when holders can redeem at par, fees and timing.
• Capital, liquidity and risk management as required by your regulator.
• BSA/AML and sanctions program: customer identification, transaction monitoring, suspicious activity reporting, sanctions screening, and the technical ability to comply with lawful orders (e.g. freezing tokens).
• Governance: board, management, fit-and-proper information on officers and directors (individuals convicted of certain financial crimes are barred).
• Technology and cybersecurity: smart contract controls, key management, operational resilience and third-party risk.
• Disclosure framework: monthly reserve reporting, accountant examination, CEO/CFO certification.

4. Submit and manage the review

Once a regulator informs you that your application is complete, it must render a decision within 120 days. Under the statute, an application not acted on within that period is deemed approved. A denial must be explained and can be followed by a hearing request.

In practice, the time needed to reach a "complete" application (and to answer follow-up questions) is often longer than the formal review window. Organizations aiming to operate on day one of the regime should plan accordingly.

5. Operate in compliance after approval

• Publish the composition of reserves monthly on your website, examined by a registered public accounting firm, with CEO and CFO certification.
• If outstanding issuance exceeds $50 billion, publish audited annual financial statements.
• Do not pay interest or yield to holders.
• Do not market the stablecoin as backed, guaranteed or insured by the US government or the FDIC.
• Maintain your AML/sanctions program and supervisory reporting.

Special case: foreign issuers

Foreign issuers can access the US market if Treasury determines their home jurisdiction's regime is comparable (Treasury must decide within 210 days of a request). Additional conditions apply, including registration with the OCC, holding sufficient reserves in US financial institutions for US customers' liquidity, and complying with lawful US orders.

From July 18, 2028, digital asset service providers may no longer offer or sell to US persons payment stablecoins that are not issued by a permitted issuer (or an eligible foreign issuer).

Readiness checklist

1. Legal analysis confirming the token is a payment stablecoin.
2. Pathway selected (bank subsidiary / federal / state) and regulator identified.
3. Reserve, custody and redemption design documented.
4. AML/BSA and sanctions program drafted, with a named compliance officer.
5. Accounting firm engaged for monthly reserve examinations.
6. Technology controls (freeze, burn, key management) tested.
7. Application timeline mapped against January 18, 2027.