Treasury asked 87 questions about stablecoins and gave itself three months to answer them

Treasury's proposal for how the GENIUS Act will be enforced appeared in the Federal Register on 18 August 2026, Volume 91, Number 158, under RIN 1505-AC95 [2]. Comments close on 19 October 2026 [2]. The statute it implements is expected to take effect on 18 January 2027 [1].

Treasury announced it on 17 August 2026. “Treasury welcomes input from stakeholders as we work to provide the regulatory certainty businesses need to innovate and grow in America, cement the role of the U.S. dollar as the world’s reserve currency, and keep America the crypto capital of the world,” said Treasury Secretary Scott Bessent [1][3][4]. Certainty is what everyone building here has been asking for. The document that offers it carries 87 numbered questions Treasury has not answered.

Do that arithmetic before you read anything else. From the day the comment file closes to the day the prohibition starts is three months, and inside those three months Treasury has to read every submission and write a final rule. Anyone waiting for settled text before they scope the work is waiting for something that arrives after the deadline it governs.

What section 3 actually stops you doing

From 18 January 2027 a person generally may not issue a payment stablecoin in the United States without an appropriate federal or state licence [1]. From the same date, a digital asset service provider may not offer, sell or otherwise make available a foreign-issued payment stablecoin unless the foreign issuer has the technological capability to comply with, and will comply with, the terms of any lawful order and any reciprocal arrangement between the United States and its home jurisdiction [1].

The wider prohibition waits until 18 July 2028, three years after enactment. On that date a digital asset service provider generally may not offer or sell any payment stablecoin to a person in the United States unless a permitted issuer issued it [1][2].

The proposal adds a new part 1523 to subchapter C of chapter XV of title 12 of the Code of Federal Regulations, with sections covering scope and definitions, issuance, offer and sale, exemptions and safe harbours, and severability [2]. Proposed section 1523.1 defines terms the Act leaves open, including issue and located in the United States, and states plainly that the part is intended to have extraterritorial effect where the conduct involves an offer or sale to a person located in the United States [2].

An issuer is also a service provider

Treasury considered whether the Act should be read as treating issuers of payment stablecoins and digital asset service providers as mutually exclusive categories, and concluded that the better reading is that an issuer can simultaneously be a digital asset service provider [2]. Proposed section 1523.1(c) then defines digital asset service provider by cross-reference to the Act, adding that the term includes a person who, for compensation or profit, engages in the business in the United States of issuing payment stablecoins [2].

Read as a scoping document, that is two compliance programmes rather than one. If the plan was to obtain a licence and work to the issuer chapter, the proposal says the service-provider obligations sit on top of that and always did. Scoping a regulated build off half a rulebook is a cheap mistake to make and an expensive one to find, because you find it at the point where the thing is already built.

Treasury also chose a narrow test for when issuance happens in the United States rather than a broader idea of nexus, and says in the preamble that it did so partly because violations of section 3(a) may carry criminal penalties, citing Executive Order 14294 on overcriminalisation in federal regulations [2]. A rule that can put someone in prison should describe the conduct precisely. The reasoning is in the document, which is why the definition is tight rather than generous.

A different deadline closes on Friday

While the new file opens, an older one shuts. FinCEN, jointly with the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the National Credit Union Administration, has a proposed rule out that treats permitted payment stablecoin issuers as financial institutions under the Bank Secrecy Act and requires each to run a customer identification programme [5]. It carries RIN 1506-AB74, it published on 22 June 2026, and comments close on 21 August 2026 [5].

That is two days from now. Five agencies wrote it, it decides how a stablecoin issuer identifies the people holding its token, and the window on it closes while the industry reads a document published on Tuesday.

Read from the rails

Yesterday this desk covered a coalition of more than twenty-five payments companies forming to work on agent identity and authorisation standards. Today the government published its own text on who may issue the instrument those agents would settle in. Neither of those is a product launch, and the rest of the beat was quiet. The searches this desk ran today turned up no new protocol and no new checkout integration in the twenty-four hours between them.

Rules get written in a comment file that almost nobody reads, and the reading gets done later by whoever has to build against the result.

So the licence is only half of what anybody shipping into this has to answer for. The service-provider obligations attach as well, and the two live rulemakings that settle both of them close two months apart. Treasury's notice runs to 24 Federal Register pages and carries 87 numbered questions, counted in the published text [2]. Question 35 asks whether issuance in the United States should turn on where the parties are, or on something broader such as the use of United States financial institutions or payment rails [2]. Treasury put that one to the industry rather than answering it, and whatever comes back becomes the definition everybody builds against on 18 January 2027.