The U.S. Department of the Treasury has presented a detailed draft of regulatory requirements designed to move the provisions of the GENIUS Act from the realm of legislative declarations into practical application. This document is the first step toward creating a full-fledged federal infrastructure for payment stablecoins, and its significance for the market can hardly be overstated.
The Essence of the Regulator's Proposals
The published Notice of Proposed Rulemaking (NPRM) focuses on implementing Section 3 of the law signed in July 2025. It concerns specifying which tokens will be considered payment stablecoins, how their issuance and circulation should proceed, as well as delineating jurisdiction and supervisory powers. In essence, the Treasury is now determining who exactly, and under what conditions, will be able to participate in the new regime.
Requirements for Issuers and Reserves
A key element of the GENIUS Act is strict collateral rules. Each payment stablecoin must be backed by reserves at a 1:1 ratio, with the list of permissible assets strictly limited. It includes only highly liquid instruments: cash dollars, bank deposits, and short-term U.S. Treasury bonds.
In addition, the law requires regular disclosure of reserve composition and independent audits. The main goal is to guarantee holders the ability to redeem coins at par at any time and to minimize systemic risks to financial stability. It is important to emphasize that the new regime does not imply government insurance for these assets: the FDIC has already made it clear that stablecoin holders will not receive protection similar to bank deposit insurance.
Public Consultation Stage
The published document is only a draft, not final rules. The Treasury has opened a comment collection period for market participants, giving the industry the opportunity to adjust regulatory initiatives before they take effect. This is already the second such initiative: in April, the agency proposed rules concerning the interaction of the federal regime with state-level regulation.
It is worth recalling that the deadline set by the law for issuing the regulatory framework expired on July 18. The full launch of the regime is expected no later than 120 days after the publication of the final rules. In parallel, work continues in the Senate on the CLARITY Act, a bill on the digital asset market structure, the final version of which could have additional impact on stablecoin regulation.
My analysis: The fact that the Treasury delayed the publication of the rules points to the complexity of balancing innovation with the protection of the financial system. However, the proposed approach with strict reserve requirements is a clear signal to the market: the era of "gray" collateral schemes is ending. In the short term, this could lead to market consolidation, where only issuers with real liquidity and transparent reporting will survive.