When does the GENIUS Act take effect?

The GENIUS Act was enacted July 18, 2025. Its implementing rules were due at the one-year statutory deadline of July 18, 2026, with six federal agencies — the OCC, FDIC, NCUA, Treasury, FinCEN, and OFAC — responsible for finalizing them. The Act itself takes effect the earlier of January 18, 2027, or 120 days after the final rules are issued.

Is a specific stablecoin like USDC or USDT 'GENIUS Act compliant'?

StableLens does not certify legal compliance, eligibility, or issuer authorization. What we publish is a methodology classification of how each stablecoin's public data aligns with the GENIUS Act framework — shown as the GENIUS alignment column in the per-coin matrix above. Treat it as one diligence input, not a legal determination, and confirm any compliance question with qualified counsel.

What is a permitted payment stablecoin issuer (PPSI)?

Under the GENIUS Act, a permitted payment stablecoin issuer (PPSI) is an entity authorized to issue a payment stablecoin in the United States — for example a subsidiary of an insured depository institution, a federally qualified nonbank issuer approved by the OCC, or a state-qualified issuer under an approved state regime. Treasury rulemaking treats PPSIs as financial institutions for Bank Secrecy Act and anti-money-laundering purposes.

Do stablecoin holders get FDIC deposit insurance under the GENIUS Act?

No. The FDIC has confirmed that payment stablecoin holders do not receive deposit insurance, regardless of whether the issuer is affiliated with a bank. A stablecoin is a claim on the issuer's reserves, not an insured bank deposit — a structural distinction the StableLens methodology weights under reserves and regulatory status.

Can a stablecoin pay yield to holders under the GENIUS Act?

The GENIUS Act prohibits permitted issuers from paying yield or interest to holders simply for holding the token, and the OCC's proposed rules would extend that prohibition to affiliates and third parties. Yield tied to bona-fide activity — such as lending or liquidity provision through a separate protocol — is a distinct question that the StableLens yield-source taxonomy tracks on the /yields surface.

Methodology classification · not legal advice

Stablecoin Regulatory Framework Alignment

Methodology classifications under the CLARITY Act (H.R. 3633), GENIUS Act, and MiCA frameworks. StableLens evaluates public-data alignment with statutory and regulatory frameworks — we do not certify compliance, eligibility, registration, or issuer authorization. Audit-trail defensible. Updated weekly.

Framework status

CLARITY Act

Proposed legislation

H.R. 3633

H.R. 3633 FAILED Senate cloture 49-50 on September 15, 2026 — ten votes short of the 60 needed, with four Republicans (Moran, Paul, Hawley, Tillis) joining all Democrats against. The bill is shelved through the November midterms; digital-asset market-structure oversight stays with the SEC and CFTC under existing law. StableLens classifications continue to track the final published draft as a methodology framework — it remains the best-articulated public taxonomy — but CLARITY is not law and is not currently advancing.

StableLens tracks the published draft as of 2026-09-28. Per-coin classifications populate the matrix below once owner + counsel review of the proposed draft completes. CLARITY is NOT yet enacted law.

GENIUS Act

Enacted

Enacted July 18, 2025. Its one-year statutory rulemaking deadline falls July 18, 2026 — six federal agencies (OCC, FDIC, NCUA, Treasury, FinCEN, OFAC) are finalizing implementing rules. The Act takes effect the earlier of January 18, 2027 or 120 days after final rules. OCC's proposal sets a $5M minimum capital floor and same-day redemption liquidity tiers; the FDIC confirms stablecoin holders receive no deposit insurance. Issuers are prohibited from paying yield to holders for holding the token; OCC proposed rules would extend that prohibition to affiliates and third parties.

StableLens encodes the current published framework. The Approved / Watch / Avoid / Insufficient Data classification on the matrix below reflects GENIUS-framework alignment as scored by the StableLens methodology v2.0.

MiCA (EU)

In force

Reg. (EU) 2023/1114

In force across EU member states since 2024-06-30. Stablecoin-specific provisions (Title III + Title IV) apply to e-money tokens and asset-referenced tokens. ESMA white-paper registration status surfaced in the matrix below.

Per-coin alignment matrix

Top stablecoins by market cap with their current methodology classifications across the three frameworks. CLARITY classifications populate as F-4.b data ingestion completes.

Symbol	Issuer	Market cap	Compliance grade	GENIUS alignment	CLARITY	MiCA
USDT Tether	Tether	$183.76B	B	Watch	Pending	See issuer
USDC USD Coin	Circle	$74.02B	A	Approved	Pending	See issuer
USDS USDS	Sky (formerly MakerDAO)	$9.91B	C+	Watch	Pending	See issuer
USDE Ethena USDe	Ethena Labs	$4.86B	C	Watch	Pending	See issuer
DAI Dai	MakerDAO	$4.59B	C+	Watch	Pending	See issuer
USD1 USD1	World Liberty Financial	$4.41B	C	Watch	Pending	See issuer
USDT0 USDT0	Everdawn Labs	$4.06B	B-	Watch	Pending	See issuer
XAUT Tether Gold	Tether	$3.38B	D	Avoid	Pending	See issuer
USDG Global Dollar	Paxos	$3.17B	A	Approved	Pending	See issuer
PYUSD PayPal USD	Paxos / PayPal	$2.76B	A+	Approved	Pending	See issuer
RLUSD Ripple USD	Ripple	$2.40B	A	Approved	Pending	See issuer
USDY Ondo US Dollar Yield	Ondo Finance	$2.28B	B-	Watch	Pending	See issuer
PAXG PAX Gold	Paxos	$1.81B	D	Avoid	Pending	See issuer
USDD USDD	TRON DAO Reserve	$1.53B	B	Watch	Pending	See issuer
U United Stables	—	$1.50B	D	Avoid	Pending	See issuer
USDF Falcon USD	Falcon Finance	$1.37B	B-	Watch	Pending	See issuer
BFUSD BFUSD	Binance	$1.32B	B-	Watch	Pending	See issuer
USDGO USDGO	Anchorage Digital Bank N.A.	$1.19B	A-	Watch	Pending	See issuer
GHO GHO	Aave DAO	$698M	C+	Watch	Pending	See issuer
USD0 Usual USD	Usual Protocol	$546M	B-	Watch	Pending	See issuer
KAU Kinesis Gold	Kinesis Money	$533M	D	Avoid	Pending	See issuer
YLDS YLDS	—	$506M	D	Avoid	Pending	See issuer
USDTB USDtb	Ethena Labs	$496M	B	Watch	Pending	See issuer
TUSD TrueUSD	Archblock (TrustToken)	$494M	B+	Watch	Pending	See issuer
EURC EURC	Circle	$467M	D	Avoid	Pending	See issuer
A7A5 A7A5	—	$459M	F	Avoid	Pending	See issuer
SOFIUSD SoFi USD	SoFi Bank, N.A.	$331M	B-	Watch	Pending	See issuer
FDUSD First Digital USD	First Digital Labs	$324M	B+	Watch	Pending	See issuer
APXUSD apxUSD	—	$320M	D	Avoid	Pending	See issuer
BUSD Binance-Peg BUSD	Binance (Paxos)	$283M	B-	Watch	Pending	See issuer
CRVUSD crvUSD	Curve Finance	$230M	C+	Watch	Pending	See issuer
KAG Kinesis Silver	Kinesis Money	$222M	D	Avoid	Pending	See issuer
AUSD AUSD	—	$219M	C	Watch	Pending	See issuer
FRAX Frax	Frax Finance	$218M	C+	Watch	Pending	See issuer
USX USX	dForce	$214M	C+	Watch	Pending	See issuer
EURCV EUR CoinVertible	—	$190M	F	Avoid	Pending	See issuer
USAT USAT	—	$183M	D	Avoid	Pending	See issuer
JPYC JPY Coin	—	$134M	F	Avoid	Pending	See issuer
CASH CASH	—	$130M	D	Avoid	Pending	See issuer
JPYSC JPYSC	—	$127M	F	Avoid	Pending	See issuer
AVUSD Avant USD	—	$125M	C	Watch	Pending	See issuer
AIDAUSDC Gaib AI Dollar Alpha USDC	—	$115M	D	Avoid	Pending	See issuer
FRXUSD Frax USD	Frax Finance	$102M	B	Watch	Pending	See issuer
USDC.N Noble USDC	—	$98M	C	Watch	Pending	See issuer
USDA USDa	Angle Protocol	$95M	C+	Watch	Pending	See issuer
FXUSD f(x) Protocol fxUSD	—	$89M	C	Watch	Pending	See issuer
CUSD Cap USD	Cap Finance	$87M	B	Watch	Pending	See issuer
USDAT Saturn Dollar	—	$86M	C	Watch	Pending	See issuer
PGOLD Pleasing Gold	—	$81M	F	Avoid	Pending	See issuer
TRUSD Tori trUSD	—	$78M	C	Watch	Pending	See issuer
MUST Mustang	—	$78M	F	Avoid	Pending	See issuer
USDSUI USDsui	—	$77M	C	Watch	Pending	See issuer
SUSDA sUSDa	—	$76M	D	Avoid	Pending	See issuer
CGUSD Cygnus Finance Global USD	—	$76M	D	Avoid	Pending	See issuer
LISUSD Lista USD	—	$76M	C	Watch	Pending	See issuer
DOLA DOLA	Inverse Finance	$76M	C+	Watch	Pending	See issuer
FEUSD Felix feUSD	—	$75M	C	Watch	Pending	See issuer
USDX USDX	—	$75M	D	Avoid	Pending	See issuer
BRLV Crown BRLV	—	$71M	F	Avoid	Pending	See issuer
USDON Ondo U.S. Dollar Token	—	$62M	C	Watch	Pending	See issuer

Methodology vs. CLARITY — alignment + gaps

Explicit map of where the StableLens 6-dimension compliance methodology aligns with CLARITY classification criteria, where the bill is silent, and where our framework goes further. This page tracks the published draft — read with the methodology versioning in mind.

StableLens dimension	CLARITY treatment	Alignment
Treasury & Reserves StableLens weight 25%	Reserve composition + qualifying-asset rules are central to CLARITY classification criteria.	Aligned Methodology inputs (cash, T-bills, attestation cadence) map directly to the bill's qualifying-asset framing.
Regulatory Status StableLens weight 20%	Issuer-licensing requirements feed the CFTC vs SEC classification path.	Aligned NYDFS Trust Charter, FinCEN MSB registry, MAS DPT, and MiCA white-paper status all feed this dimension.
Peg Stability StableLens weight 20%	Peg-maintenance language present but specific deviation thresholds not codified.	Methodology extends Methodology specifies a 75bps 24h deviation threshold; published draft is silent on exact bps.
Audit & Code Security StableLens weight 15%	Smart-contract audit posture is not directly addressed in the published draft.	Bill silent StableLens grades audit firm tier + exploit history; bill leaves this to operational supervision.
Issuer Operational Health StableLens weight 10%	Engineering continuity + redemption infrastructure not codified.	Methodology extends Methodology surfaces operational signals (GitHub activity, redemption uptime) the bill does not.
Historical Behavior StableLens weight 10%	Past peg defenses + attestation-vs-reality reconciliation not codified.	Methodology extends Methodology surfaces depeg event archive + statement-vs-outcome history beyond statutory minimum.
Yield-source taxonomy F-4.c — pending	Tillis-Alsobrooks distinction (passive balance yield vs activity-based rewards) under consideration.	Partial Yield-source classification surfacing in F-4.c; aligns with the bill's reward-taxonomy framework once seeded.

Yield-source distinction under CLARITY

The Tillis-Alsobrooks compromise (Section 404, finalized May 5, 2026) distinguishes interest-like payments from rewards tied to user action. The compromise text is settled; the permissible-reward definitions and anti-evasion rules are not — they require joint SEC / CFTC / Treasury rulemaking due within 12 months of enactment, and CLARITY is not yet enacted. The framework below describes how StableLens reads the current draft language; treat all yield classifications as provisional pre-rulemaking.

Passive balance yield (likely banned)

Payments “economically or functionally equivalent” to bank-deposit interest — paid to holders just for holding the token, with no user action required. The Section 404 text directly targets this category. Examples include holder-rewards programs and interest-bearing wrapped stablecoins paying yield without an associated activity.

Activity-based rewards (generally permitted)

Rewards tied to “bona fide activities” — providing liquidity to an AMM, lending through a money-market protocol, participating in governance, or staking with genuine slashing risk. The draft text generally preserves these. Caveat: banking trade associations (ABA, BPI, CBA, Financial Services Forum, ICBA) flagged reward structures based on duration, balance, or tenure as a potential loophole on May 4, 2026 — anti-evasion rulemaking is expected to scrutinize those structures specifically.

What this means for allocation

Treasury desks evaluating stablecoin yield benefit from making the Tillis-Alsobrooks distinction explicit in IC memos. StableLens encodes it via the yield_source_type + clarity_yield_status columns on public.yield_pools (F-4.c migration). Per-pool classifications are unseeded pending owner + counsel review; until seeded, all pools render a methodology classification of unclear. Rewards tied to duration / balance / tenure carry elevated banned risk pending joint rulemaking.

Filter the live universe by CLARITY treatment at /yields?clarity=allowed. Each pool’s persisted reasoning is exposed via the row tooltip on /yields. This is methodology classification, not a legal determination — see the disclaimer below.

GENIUS Act — frequently asked

Common questions about the GENIUS Act and how StableLens reads it. These are methodology explanations, not legal advice — see the disclaimer below.

When does the GENIUS Act take effect?: The GENIUS Act was enacted July 18, 2025. Its implementing rules were due at the one-year statutory deadline of July 18, 2026, with six federal agencies — the OCC, FDIC, NCUA, Treasury, FinCEN, and OFAC — responsible for finalizing them. The Act itself takes effect the earlier of January 18, 2027, or 120 days after the final rules are issued.
Is a specific stablecoin like USDC or USDT 'GENIUS Act compliant'?: StableLens does not certify legal compliance, eligibility, or issuer authorization. What we publish is a methodology classification of how each stablecoin's public data aligns with the GENIUS Act framework — shown as the GENIUS alignment column in the per-coin matrix above. Treat it as one diligence input, not a legal determination, and confirm any compliance question with qualified counsel.
What is a permitted payment stablecoin issuer (PPSI)?: Under the GENIUS Act, a permitted payment stablecoin issuer (PPSI) is an entity authorized to issue a payment stablecoin in the United States — for example a subsidiary of an insured depository institution, a federally qualified nonbank issuer approved by the OCC, or a state-qualified issuer under an approved state regime. Treasury rulemaking treats PPSIs as financial institutions for Bank Secrecy Act and anti-money-laundering purposes.
Do stablecoin holders get FDIC deposit insurance under the GENIUS Act?: No. The FDIC has confirmed that payment stablecoin holders do not receive deposit insurance, regardless of whether the issuer is affiliated with a bank. A stablecoin is a claim on the issuer's reserves, not an insured bank deposit — a structural distinction the StableLens methodology weights under reserves and regulatory status.
Can a stablecoin pay yield to holders under the GENIUS Act?: The GENIUS Act prohibits permitted issuers from paying yield or interest to holders simply for holding the token, and the OCC's proposed rules would extend that prohibition to affiliates and third parties. Yield tied to bona-fide activity — such as lending or liquidity provision through a separate protocol — is a distinct question that the StableLens yield-source taxonomy tracks on the /yields surface.

See each coin’s GENIUS alignment in the per-coin matrix above, or browse all stablecoins.

What this is — and is NOT

StableLens evaluates how stablecoins and yield mechanisms align with the current text of selected regulatory frameworks. The CLARITY Act (H.R. 3633) is not law and is not currently advancing — it failed Senate cloture 49-50 on September 15, 2026 and is shelved through the midterms; market-structure oversight stays with the SEC and CFTC under existing law. Classifications continue to track the final published draft as of 2026-09-28 as a methodology framework only. The GENIUS Act is enacted and unaffected: implementing rules were due at its July 18, 2026 statutory deadline, and the Act takes effect the earlier of January 18, 2027 or 120 days after final rules.

Yield-source classifications reflect StableLens’s reading of the Tillis-Alsobrooks compromise text. The permissible-reward definitions and anti-evasion rules require joint SEC / CFTC / Treasury rulemaking that has not yet occurred. Treat all yield classifications as provisional.

StableLens does not certify legal compliance, eligibility, registration, or issuer authorization. Classifications are methodology outputs, not legal determinations, and create no attorney-client relationship. Use as one input among many in regulatory diligence; always confirm with qualified counsel before any material decision. Methodology version, last-reviewed timestamp, and data-source disclosure: /methodology.

View full methodology →·Browse all stablecoins·llms.txt

Page last reviewed 2026-09-28. Framework status reviewed weekly. Per-coin classifications refresh on the 10-minute cron cadence shared by the rest of the StableLens platform.