From reserve necessities to international issuer guidelines, the OCC’s GENIUS Act proposal maps out what a federal stablecoin framework will imply for enterprise funds – and when it takes impact
Eight months after the GENIUS Act was signed into legislation, the federal framework for fee stablecoins is beginning to take form.
On 25 February 2026, the Workplace of the Comptroller of the Foreign money (OCC) issued a discover of proposed rulemaking, which set out the rules it intends to use to permitted fee stablecoin issuers and international fee stablecoin issuers working beneath its jurisdiction.
It marks a big step in translating the Guiding and Establishing Nationwide Innovation for US Stablecoins (GENIUS) Act, signed on 18 July 2025, into enforceable federal guidelines.
Operating to 376 pages, the proposal covers the majority of what the OCC is required to promulgate beneath the GENIUS Act.
What the proposal covers
The proposed framework is basically housed in a brand new part of federal banking rules – 12 CFR 15 – and is accompanied by amendments to present capital adequacy requirements (12 CFR 3), immediate corrective motion guidelines (12 CFR 6), evaluation charges (12 CFR 8), and procedural guidelines (12 CFR 19).
At its core, the proposal requires:
Cost stablecoins to be backed on no less than a one-to-one foundation with identifiable, extremely liquid belongings.
Issuers to take care of clear reserves and redeem stablecoins at par worth inside two enterprise days in most circumstances.
Capital and liquidity to be calibrated to every issuer’s danger profile fairly than utilized uniformly, an method that recognises the variation in scale and complexity throughout the stablecoin market.
The OCC’s jurisdiction beneath the proposal extends to subsidiaries of nationwide banks and federal financial savings associations, federally licensed nonbank stablecoin issuers, sure state-qualified issuers, and international fee stablecoin issuers. Per the GENIUS Act, international fee stablecoin issuers should register with the OCC particularly.
In 2025, authorized evaluation by Latham & Watkins discovered the inclusion of international issuers to be consequential as abroad corporations in search of to serve US prospects wouldn’t solely be required to register with the OCC, but additionally maintain adequate reserves at a US monetary establishment to satisfy home liquidity calls for.
That requirement is probably going to attract scrutiny in markets such because the EU, UK, and Asia the place separate stablecoin regimes are already growing, provided that it applies even the place a international regime has been assessed as broadly comparable.
The proposal additionally units out a principles-based danger administration framework, encompassing cybersecurity protections, operational resilience, and third-party danger oversight, with documentation and management expectations scaled to the issuer’s dimension and complexity.
Comptroller for the OCC, Jonathan Gould, stated on its discover of proposed rulemaking: “The OCC has given considerate consideration to a proposed regulatory framework wherein the stablecoin trade can flourish in a secure and sound method.
“We welcome suggestions on the proposal to tell a ultimate rule that’s efficient, sensible and displays broad trade perspective. The OCC will proceed its work to implement the GENIUS Act and supply OCC regulated entities with extra alternatives to satisfy the wants of their prospects and communities.”
Nonetheless, not every little thing is addressed on this rulemaking. The OCC has confirmed that necessities tied to the Financial institution Secrecy Act, anti-money laundering compliance, and Workplace of International Belongings Management (OFAC) sanctions will probably be dealt with in a separate rulemaking, developed in coordination with the US Division of the Treasury.
As famous within the Federal Register, the Treasury itself issued an advance discover of proposed rulemaking in September 2025, in search of remark by itself implementing guidelines – together with the method for assessing the comparability of international regulatory regimes.
A coordinated federal effort
The OCC’s proposal is however a part of a broader interagency implementation effort. The Federal Deposit Insurance coverage Company (FDIC) was the primary main regulator to behave, publishing proposed guidelines on 16 December 2025 setting out how eligible banks may apply to subject fee stablecoins by subsidiaries.
The Nationwide Credit score Union Administration (NCUA) adopted on 11 February 2026 with its personal discover of proposed rulemaking masking credit score union subsidiaries, with a remark interval operating to 13 April 2026.
The Federal Reserve has but to publish a proper proposal, and with the clock operating, it’s presently a notable absence. Per the GENIUS Act, the laws takes impact on the sooner of 18 months after enactment – inserting the date at 18 January 2027 – or 120 days after the first federal regulators subject their ultimate implementing rules.
That deadline creates significant strain on companies to coordinate, as a result of the 120-day clock solely begins as soon as all main regulators have issued ultimate guidelines. Any vital lag by a single regulator delays the set off and pushes the efficient date in the direction of the statutory backstop of 18 January 2027, compressing the time accessible for the trade to arrange.
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