“A year in, agencies, institutions, and innovators are building on a clearer foundation, and stablecoins are moving rapidly toward mainstream adoption,” said Ji Hun Kim, CEO of the Crypto Council for Innovation, in an emailed statement to CoinDesk.
One year after President Donald Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act into law, federal regulators are still working through the process of actually writing the rules. The landmark legislation, which became the first major federal law specifically targeting cryptocurrency in American history, established a broad framework for stablecoin governance. The details, however, remain unfinished business.
The anniversary arrives at an awkward moment. Industry participants have spent twelve months waiting for regulatory clarity that remains several months away, while Congress continues fighting over a companion bill that would bring the rest of the digital asset market under federal oversight. The ethics provisions (or lack thereof) in that broader legislation have become a political flashpoint, with Senator Elizabeth Warren demanding updated financial disclosures from Trump showing his crypto-related earnings in 2026.
Where The Rulemaking Actually Stands
The GENIUS Act delegated the hard work to agencies. The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation are the primary regulators tasked with transforming congressional direction into enforceable requirements for Tether, USDC, and other stablecoin issuers.
The FDIC published 144 questions several months ago about how it would oversee stablecoin issuers. That document covered custody arrangements, capital standards, and liquidity requirements, essentially asking the industry to help regulators understand what guardrails make sense. The OCC followed in February with its own proposal laying out how the agency interprets the law’s requirements.
One notable element in the proposals: stablecoin issuers would need to conduct know-your-customer checks similar to those required of traditional financial institutions. That represents a significant operational burden for issuers who have historically operated with lighter compliance frameworks.
The proposals remain open for comment, and final rules are not expected for several more months. For an industry that has watched JPMorgan file an Ethereum-based treasury fund specifically designed for GENIUS Act compliance, the wait is getting long.
The Stablecoin Market During Year One
While regulators deliberate, the stablecoin sector has not stood still. Market participants have been building infrastructure in anticipation of compliance requirements, even without knowing the precise rules they will need to follow.
Consider the divergence in how major stablecoins are being used. USDT has established dominance in commerce and remittances, while USDC has become the preferred instrument for DeFi transactions. That functional split reflects different user bases and risk tolerances, and it may influence how regulators think about tiered requirements.
The anticipation of federal oversight has also pushed institutional players to prepare. JPMorgan’s JLTXX fund, filed in May, targets stablecoin issuers looking to park reserves in tokenized Treasuries. The structure was explicitly designed with GENIUS Act compliance in mind, suggesting that at least some firms expect the final rules to favor traditional financial instruments for reserve backing.
Kim’s statement about “mainstream adoption” is not merely cheerleading. Stablecoin transaction volumes have continued climbing throughout the regulatory interregnum, with both retail and institutional users treating these assets as a reliable dollar proxy despite (or perhaps because of) the incoming federal framework.
The Clarity Act Bottleneck
The GENIUS Act addressed stablecoins. The broader digital asset market, including Bitcoin, Ethereum, and the thousands of other tokens traded on exchanges, still lacks comprehensive federal oversight. That is supposed to be the job of the Digital Asset Market Clarity Act, but the bill remains stuck.
As of Friday night, the combined draft text was not public despite industry expectations that it would be released last week. Senators Cynthia Lummis and Bernie Moreno briefed Trump on the bill Thursday, though no public readout of that meeting was available afterward. Both lawmakers tweeted about Trump’s remarks on the election later Thursday, which tells you something about priorities.
The core obstacle is ethics. Democrats want provisions that would prevent senior government officials from profiting off personal cryptocurrency ventures. Republicans have not agreed to such language.
The conflict is not abstract. Trump’s 2025 financial disclosure showed over $1.4 billion in earnings from various crypto ventures. Warren sent a letter to Trump requesting a voluntary disclosure covering the first half of 2026, noting that his mandatory filing for this year is not due until May 15, 2027.
“Unfortunately, [the 2025 disclosure] is not an up-to-date reflection of your finances: it does not account for any changes that have taken place in recent months,” Warren wrote. “You are not required to file information on your Annual Report for 2026 with [the U.S. Office of Government Ethics] until May 15, 2027.”
The Trump family’s involvement in crypto extends beyond passive investments. World Liberty Financial, the family’s crypto venture, paid UFC fighter bonuses in its USD1 stablecoin at a White House event in June, drawing accusations of corruption from the DNC. The OCC has faced Democratic pressure over World Liberty’s bank charter application, with Comptroller Jonathan Gould publicly pushing back against what he characterized as political interference.
For our explainer on the GENIUS Act’s specific provisions, see our GENIUS Act stablecoin regulation guide.
What Happens Before Year Two
Rep. Bryan Steil, who chairs the House Financial Services Committee’s digital assets subcommittee, framed the stakes at a Friday hearing: “Our goal is clear: replace regulation by enforcement with clear rules of the road for digital assets.”
That phrase, “regulation by enforcement,” has been the crypto industry’s primary complaint about the pre-GENIUS era. The SEC and other agencies brought cases against crypto firms without first establishing clear rules for what was legal. The industry’s argument is that companies cannot comply with standards that do not exist.
Steil’s remarks reflect the view that the Clarity Act would extend the GENIUS framework to the rest of the market. “For 250 years, America has led the world in financial innovation,” he said. “For 15 years, blockchain technology has redefined what’s possible. For 10 years, Congress has worked to write the rules of this new financial frontier, and for one year we have had a statutory” framework for stablecoins.
The incomplete sentence is how the source article ends, but the point is clear enough. The stablecoin rules are a foundation, not a finished structure.
Several concrete milestones lie ahead. The FDIC and OCC comment periods will close, and agencies will begin drafting final rules. The Clarity Act negotiations will either produce a bipartisan text or remain deadlocked. Trump’s 2027 disclosure deadline will eventually arrive, though that is nearly ten months away.
For market participants, the practical question is whether to build for the rules they expect or wait for the rules they will actually face. The JPMorgan fund suggests at least some institutional players are betting on reserve requirements that favor tokenized Treasuries. Others may be positioning for different outcomes.
The fear and greed index and broader market data suggest that regulatory uncertainty has not prevented capital from flowing into crypto. Whether that capital is being allocated efficiently given the still-unfinished rulebook is a separate question.
The stablecoin sector specifically can track regulatory developments through our derivatives dashboard, which monitors funding rates for USDT and USDC perpetuals as proxy indicators of market stress.
A Year Of Framework, Not Rules
The GENIUS Act’s first anniversary is worth marking precisely because it illustrates the gap between legislation and implementation. Congress can pass a law in a day. Agencies need months or years to translate statutory language into operational requirements.
That gap creates uncertainty for issuers, opportunities for early movers willing to bet on regulatory outcomes, and frustration for those who expected faster clarity. Kim’s characterization of a “clearer foundation” is accurate as far as it goes. Stablecoin issuers now know that federal oversight is coming and roughly what form it will take.
But they do not yet know the specific reserve ratios, custody requirements, or KYC standards they will need to meet. They do not know which agency will be their primary regulator or what examination process they will face. They do not know how the ethics debate over the Clarity Act will resolve or whether that bill’s passage will change the stablecoin framework.
What they do know is that the old regime, where stablecoin issuers operated in a gray zone between federal and state authority, is ending. The GENIUS Act established federal primacy over this market segment. The rest is implementation.
The next major deadline to watch is the close of the FDIC and OCC comment periods, after which agencies will begin drafting final rules. Those rules will determine whether the GENIUS Act becomes a workable framework or a compliance burden that pushes activity offshore.
One year down. Several more months of rulemaking to go.
